Writers' Guild of America West, Inc. v. Superior Court

Citations: 53 Cal. App. 3d 468; 126 Cal. Rptr. 498; 91 L.R.R.M. (BNA) 2603; 1975 Cal. App. LEXIS 1580Docket: Civ. 46568

Court: California Court of Appeal; December 5, 1975; California; State Appellate Court

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The case involves the Writers' Guild of America West, Inc. (Guild) and members who faced disciplinary threats for crossing the union's picket line during a 1973 strike. The Guild, representing writers, required members to honor picket lines, which resulted in members losing potential income from contracts with struck employers. The Guild threatened members with fines and other disciplinary actions for continuing to work, leading to charges filed against the Guild with the National Labor Relations Board (NLRB) for unfair labor practices. The NLRB found the Guild guilty, and the case is under judicial review. In January 1974, the affected members filed a complaint against the Guild, asserting that the Guild's constitution did not grant it authority to discipline them for actions outside their writing roles. Their complaint, consisting of 45 causes of action, sought declaratory relief and damages for interference with contracts and business relationships, as well as claims of fraud based on the Guild's false claims of authority. The California Court of Appeals determined that the state courts lacked subject matter jurisdiction over the matter, as the allegations fell within the NLRB's jurisdiction, and issued a writ of prohibition to halt the state court proceedings.

Guild submitted a general demurrer and a motion to strike and dismiss a complaint, arguing that the National Labor Relations Act (NLRA) preempted the National Labor Relations Board's (NLRB) jurisdiction regarding the actions forming the basis of the complaint. The motion was backed by undisputed declarations detailing Guild's and the real parties' statuses, their connection to interstate commerce, the context of a strike, the rule requiring honor of the picket line, and potential disciplinary actions against Guild members for noncompliance. Although disciplinary actions were initiated against some members, they were largely dismissed, except for one instance resulting in a fine of $179.40.

The trial court overruled the demurrer and denied the motion to dismiss, prompting Guild to file a petition for a writ of prohibition or mandate. The appellate court, with one dissenting opinion, denied an alternative writ. Following a petition for hearing, the Supreme Court directed the matter back to the appellate court to issue an alternative writ, referencing Hill v. United Brotherhood of Carpenters.

The excerpt elaborates on federal preemption concerning state regulation of labor relations, noting that if activities are arguably under NLRB jurisdiction, state jurisdiction must yield. It cites various cases emphasizing that preemption applies even when state claims may involve breach of union contracts or tortious interference as long as the core issues relate to employment and are arguably within NLRB jurisdiction. The focus should be on the conduct being regulated rather than the legal labels used for the claims.

State courts do not have jurisdiction over disputes when the conduct in question is arguably within the jurisdiction of the National Labor Relations Board (NLRB). In Hill v. United Brotherhood of Carpenters, the plaintiffs, who assert supervisory status and exemption from NLRB jurisdiction, ultimately base their complaint on conduct that falls within the NLRB's scope. The National Labor Relations Act (NLRA) guarantees employees the right to self-organization and collective bargaining while prohibiting labor organizations from coercing employees in these rights. The plaintiffs allege that the Guild's actions coerced them into abandoning their right to refrain from participating in collective actions, a matter clearly under NLRB jurisdiction. 

Federal preemption applies unless exceptions exist, such as internal union matters, explicit congressional intent for state jurisdiction (e.g., collective bargaining agreements under Section 301 of the NLRA), issues traditionally left to local laws (like defamation or violence), or laws that do not undermine federal labor interests (e.g., fair representation). In this case, none of the exceptions to preemption are applicable, as the plaintiffs' claims are directly related to their employment and have immediate effects on it. Thus, the superior court lacks jurisdiction over the matter.

Congress has not explicitly granted state jurisdiction over the conduct alleged in the complaint. The real parties reference the Labor Management Reporting and Disclosure Act of 1959 (LMRDA), specifically section 101, which mandates due process for members facing disciplinary actions from labor organizations, including written charges, preparation time for defense, and a fair hearing. Although they assert that their disciplinary threats did not align with the Guild's constitution or bylaws, thereby denying them a fair hearing, the leap to claim state jurisdiction under section 103 of the LMRDA—which preserves state court remedies—despite federal preemption by the National Labor Relations Act (NLRA) is unsupported. The U.S. Supreme Court has indicated that courts cannot determine the scope of union disciplinary actions. While state law might provide broader remedies, Congress acknowledged that the LMRDA's language was more limited than many state laws. The Supreme Court also noted a potential for state courts to address union discipline cases not covered by the union's bylaws, but that does not exempt such cases from federal preemption where the conduct directly affects employment. The LMRDA enforcement was assigned to federal district courts, not the NLRB, which complicates the relationship between state remedies and federal preemption. A related case, Lockridge v. Motor Coach Employees, further illustrates that state courts lack jurisdiction for claims that are considered unfair labor practices under NLRB jurisdiction, reaffirming the preemption principle.

Justice White's dissent, joined by Chief Justice Burger, argued against the application of preemption, emphasizing that the Labor-Management Reporting and Disclosure Act (LMRDA) preserves state remedy provisions, indicating Congressional intent to allow state-based breach of contract claims that could also be considered unfair labor practices. The majority opinion dismissed this reasoning, asserting that the enforcement of the LMRDA is not under the National Labor Relations Board (NLRB). The Supreme Court, in the Motor Coach Employees v. Lockridge case, found the dissenting argument unpersuasive, clarifying that the LMRDA does not limit the preemption doctrine regarding conduct within the NLRB's jurisdiction. The dispute at hand falls within the NLRB's traditional domain, and the real parties’ claim of a California constitutional right to employment does not alter this analysis, as state constitutional provisions are similarly preempted by federal law. Furthermore, the California law in question does not avoid the risk of conflict with federal labor statutes, as preemption seeks to establish a unified legal system under expert administrative oversight. Consequently, the complaint alleges causes of action that are arguably under NLRB jurisdiction, precluding state court jurisdiction unless specific exceptions apply, which are not present here. The court ordered a peremptory writ of prohibition to dismiss the complaint, with subsequent petitions for rehearing and Supreme Court review being denied.