Dispute Only Required Reference To Collective Bargaining Agreement (CBA), Not Interpretation Of It.
I blogged about Melendez v. San Francisco Baseball Associates LLC, on December 18, 2017, when it was still in the Court of Appeal. Baseball security guards had sued the Giants, alleging that the guards were intermittent employees, entitled to be paid after they were discharged after every Giants homestand, after the end of the baseball season, and after other park events. The trial court had held that, despite the CBA between the Giants and the guards, their wage dispute was not preempted by the Labor Management Relations Act of 1947, and therefore, did not need to be arbitrated. The Court of Appeal disagreed, holding that even though the claims involved state labor law, the dispute required interpretation of the CBA, resulting in preemption, and therefore requiring arbitration.
Now the California Supreme Court has reversed the Court of Appeal. Melendez v. San Francisco Baseball Associates LLC, S245607 (Sup. Ct. 4/25/19). Justice Chin authored the unanimous opinion. The Supreme Court's analysis depends on the distinction between interpretation of the CBA, and reference to it. Balcorta v. Twentieth Century-Fox Film Corp., 208 F.3d 1102 (9th Cir. 2000) is the key case setting forth the analysis upon which Justice Chin relied.
Merely because the CBA had to be read and referenced did not mean that it had to be interpreted; its terms were not in dispute. Thus, because the claims involved independent state labor law, and not a breach of contract, and because interpretation of the CBA was not required, there was no preemption, and arbitration was not required. So: A win, at this stage, for the baseball security guards, leaving the merits to be resolved when the matter is remanded to the trial court.
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