Lockridge v. Amalgamated Ass'n of Street, Electric Railway & Motor Coach Employees of America

The majority today reaches a position which is, perhaps, tenable as a matter of pure logic.1 I can not, however, agree with them that it is the law. They attempt to fit this case within the too-narrow “internal union matter” exception to the doctrine of federal pre-emption in labor law. That niche is entirely too small to accommodate this particular action. Although this ground has been plowed here before,2 a recapitulation of the United States Supreme Court cases, and the principles which may be derived therefrom, may serve to indicate more precisely the errors upon which the majority…