Clearing up some confusion among the lower federal courts, the Sixth Circuit confirms that the Labor-Management Relations Act (LMRA) § 301 does not supersede an employee's federal statutory right to file a civil action to remedy a violation of her rights under the ADA.
Watts v. UPS, No. 11-3480 (6th Cir. Dec. 12, 2012): Various courts have held that the mandatory-arbitration procedures of the federal Railway Labor Act may override a covered employee's right in the railroad/airline industry to proceed to court with an ADA claim. Some have attempted to extend this exclusive-remedy argument to the right of action provided by the LMRA § 301 to enforce the terms of a collective bargaining agreement. But in today's decision, the Sixth Circuit holds that there is no conflict between the LMRA and the ADA.
The employee, Ms. Watts, returned from recovering from back strain and sought assignment to light duty, termed Temporary Alternative Work (TAW). UPS contended that "she was not qualified for the program and point[ed] to language in the collective bargaining agreement (CBA) as support for its interpretation of the TAW program requirements." Ms. Watts claimed that failure to assign her to TAW violated her ADA right to a reasonable accommodation.
The district court - which conducted two jury trials reaching different results - dismissed Ms. Watts ADA (on UPS's motion for judgment as a matter of law). It so held on the ground that the claim was supposedly "preempted by § 301 of the Labor Management Relations Act (LMRA), and was untimely under the [LMRA's] six-month statute of limitations." The essential argument was that because the TAW program was a product of the collective bargaining agreement, the court only had the authority to interpret and enforce the CBA terms under the LMRA.
The Sixth Circuit reverses. In a brief opinion, the panel holds that the district court misapplied such precedents as Allis-Chalmers v. Lueck, 471 U.S. 202 (1985), and Lingle v. Norge Div. of Magic Chef, Inc., 486 U.S. 399 (1988). Those cases concerned state-law claims, which are subject to preemption under the federal supremacy clause of the U.S. Constitution. As various district courts have held, though, LMRA § 301 has no such effect on federal-law claims, such as under the ADA: "[T]he the right to be free from disability discrimination that Watts seeks to vindicate in this action does not arise from the CBA or from state law; rather, it is founded on the ADA."
The panel also rejects analogy to the RLA. "UPS has not argued that Watts was subject to a mandatory arbitration agreement under the CBA that she failed to exhaust before bringing her ADA claim in federal court. RLA cases are therefore distinguishable and do not advance UPS's position."
Thus, while there may be cases where state-law disabilities discrimination claims might be subject to preemption, federal ADA claims are not superseded by the LMRA.