Philip Crosby v. Cooper B-Line, Incorporated

WOOD, Circuit Judge.

The Supreme Court has held that Section 301 of the Labor Management Relations Act (LMRA), 29 U.S.C. § 185, preempts all state-law claims that require the interpretation of a collective bargaining agreement (CBA) or any other covered labor contract. This rule, which goes under the clumsy name of “complete preemption” (a better term might be “complete displacement”), covers not only obvious disputes over labor contracts, but also any claim masquerading as a state-law claim that nevertheless is deemed “really” to be a claim under a labor contract. These cases are understood…