Brief Fact Summary.
Former employees (Respondents) sued Caterpillar Tractor Co. (Petitioner) under state law for laying them off after guaranteeing job security. Petitioner removed the case.
Synopsis of Rule of Law.
A claim cannot be removed unless the claim originally could have been filed in federal court.
Section 301 governs claims founded directly on rights created by collective-bargaining agreements, and also claims substantially dependent on analysis of a collective-bargaining agreement.View Full Point of Law
Caterpillar Tractor Co. (Petitioner) hired individuals (Respondents) to work at its facility under a collective bargaining agreement. Each Respondent eventually became a managerial or salaried employee not covered by the collective bargaining agreement, assured by Petitioner that they would remain employed even if the facility was closed. When the facility closed, all Respondents were laid off. Respondents filed suit against Petitioner for violation of state law. Petitioner removed the case on the ground that federal labor law was implicated by the collective bargaining agreement. Respondents moved to send the case back to state court because they had not plead any federal claim.
Can the claims be removed on the basis of the Petitioner’s defense, when no federal law was raised in the Respondent’s complaint?
No, the Respondents’ claims cannot be removed because they did not arise under federal law. The Appeals Court is affirmed.
This claim could not have originally been filed under federal question jurisdiction because it did not satisfy the well-plead complaint rule. The Respondents’ claims were not related to the collective bargaining agreement and anticipated defenses under federal law do not satisfy the well-plead complaint rule.