Williams v. National Football League case brief

Williams v. National Football League case brief summary
582 F.3d 863 (2009)

CASE SYNOPSIS

Defendant national sports league challenged the U.S. District Court for the District of Minnesota's order finding that the Minnesota statutory claims alleged by plaintiff players were not preempted by § 301 of the Labor Management Relations Act (LMRA), 29 U.S.C.S. § 185. The players cross-appealed the district court's finding that their Minnesota common law claims were preempted by § 301.

CASE FACTS

In addition to the other appeals, plaintiff players' union challenged the confirmation of arbitration awards upholding the players' suspensions for using bumetanide, a banned prescription diuretic contained in a dietary supplement, in violation of a policy incorporated into the collective bargaining agreement (CBA) between the league's management council and the union.

DISCUSSION

• On appeal, the court agreed that the players' claims under Minnesota's Drug and Alcohol Testing in the Workplace Act, Minn. Stat. §§ 181.950-181.957, were not preempted by LMRA because the players alleged the violation of nonnegotiable state law rights that did not require the court to interpret the CBA. 
• The players' Consumable Products Act, Minn. Stat. § 181.938, claim was not preempted because it also did not require the court to interpret the CBA; further, it was not waived by the union's having agreed to certain drug testing procedures and discipline under the CBA. 
• The players' Minnesota common law claims were preempted by LMRA because they were inextricably intertwined with the CBA. 
• The arbitration awards were enforceable under the Federal Arbitration Act, 9 U.S.C.S. § 10(a).

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