Brown v. Garman

WOLLE, Justice.

This interlocutory appeal presents the threshold jurisdictional question whether federal labor relations laws preempt damage claims asserted by a union member against union officials for (1) intentional infliction of emotional distress, and (2) intentional interference with contractual relations and employment opportunities. The district court dismissed both claims on the ground that the preemption doctrine deprives the state court of jurisdiction to decide them. We conclude that federal law preempts only the claim of interference with contractual and employment opportunities,…