Banfield v. Laidlaw Waste Systems

OPINION

ROACH, Justice.

Benjamin Allen Banfield and Robert Lindsey appeal the trial court’s summary judgment in favor of Laidlaw Waste Systems. In two points of error, Banfield and Lindsey assert the trial court erred in determining that the National Labor Relations Act (NLRA) 1 preempts their claims for wrongful discharge asserted under the Texas Right to Work Law and their common law defamation claims. Because we conclude that (1) the wrongful discharge claims are preempted by the NLRA, and (2) the statements comprising the basis of appellants’ defamation claims are not defamatory as a matter…