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Kaufman v. Allied Pilots Association

Garmon preemption extends to all types of state regulation that conflicts with federal labor relations law, whether that is by state statute or state judicial supervision, whether in litigation between parties to the labor relationship or between downstream injured persons and parties to the labor relationship.

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Appeal from the United States District Court for the Northern District of Texas

A union of airline pilots violated the order of a federal court by continuing its work slowdown. The union has since paid substantial fines for violating the order and now faces suits seeking money damages under state law for the stoppage damages caused by the slowdown activity that violated the court order. These claimants attempt to run their state claims around Garmon preemption under an argument that state law would not here interfere with the federal labor machinery and its distinct remedial schemes for labor peace because the conflict complained of violates a federal court order. At the same time the state law claimants argue that they are not seeking to supplement the federal order by their suits. The district court accepted these arguments. We do not and reverse. We are persuaded that the claims are preempted under the Garmon doctrine and do not reach the question of preemption under the Airline Deregulation Act.

I.

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