United Steelworkers of America, AFL-CIO-CLC v. Rawson

The Idaho Supreme Court held that summary judgment was improper and that Tharon Rawson and the other respondents could proceed to trial against the United Steelworkers of America (Union) on a state-law tort theory. Although the respondents have not yet established liability under Idaho law, the Union argues that federal law must govern and bar their suit. To support this position, the Union relies on both §301 of the Labor Management Relations Act, 29 U. S. C. § 185(a), and the duty of fair represen*377tation implicit in §9(a) of the National Labor Relations Act (NLRA), 49 Stat. 453, as amended,…