Local 174, Teamsters, Chauffeurs, Warehousemen Helpers v Lucas Flour Co.
PROCEDURAL
POSTURE: Certiorari was issued to the Supreme Court of Washington to
determine whether the Labor Management Relations Act, 29 U.S.C.S. 185,
applied in an action in which a state court applied state law to find
that petitioner union violated a collective bargaining contract with
respondent employer by calling a strike to force respondent to rehire an
employee.
OVERVIEW:
The judgment finding petitioner union violated a collective bargaining
contract by striking to settle a contract dispute was affirmed where the
contract called for arbitration to resolve disputes. Respondent fired
an employee for unsatisfactory work. Petitioner called a strike to force
respondent to rehire the employee. Respondent brought suit in the state
trial court, asking for business loss damages. The trial court applied
principles of state law and found for respondent where the strike
violated the contract and was an attempt to coerce respondent to forgo
its contractual right to discharge an employee for unsatisfactory work.
Petitioner appealed. The state appellate court affirmed. Petitioner
again appealed. The Supreme Court affirmed, holding that although
federal labor law pre-empted state law where a conflict existed,
affirmance was proper where petitioner violated the agreement despite
the absence of a no-strike clause in the contract. A strike to settle a
collective bargaining agreement violated the agreement because the
agreement called for arbitration proceedings to settle disputes.
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