Washington v. Union Carbide Corp.

WILKINSON, Circuit Judge:

This case raises questions about the proper method of resolving claims that a state-law cause of action is preempted under § 301 of the Labor Management Relations Act. We hold that it lies within the discretion of a federal district court, in an appropriate case, to address the state claim on the merits before resolving the § 301 preemption inquiry.

Thomas E. Washington brought this action in federal district court after being fired from his position at Union Carbide’s facility in South Charleston, West Virginia. He alleged, inter alia, that Union Carbide violated the…