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Contract Services Employee Trust, Board of Trustees, a Multi-Employer Plan Contract Services Employee Trust, a Multi-Employer Plan, and Local 211 Contract Services Union, an Oklahoma Not-For-Profit Corporation, a Division of Financial Consultants Guild of America Contract Services Network, Inc., a New York Corporation v. Marcia Davis, an Administrator of the Oklahoma Workers' Compensation Court Dave Renfro, as Commissioner of the Oklahoma State Department of Labor, and Bradley D. Archer Ray B. Wingate Van C. Johnson David M. Sturgeon Nickey N. Owens State Insurance Fund, State of Oklahoma Elton Newsom Keith Swafford Eric Bejcek Bruce Jacob John Knox Danny Morris Yolanda Comba Donald Hume Jerald Bailey Elgin Beavers John Frederick Bruder

Citations: 55 F.3d 533; 149 L.R.R.M. (BNA) 2587; 1995 U.S. App. LEXIS 12292Docket: 93-6373

Court: Court of Appeals for the Tenth Circuit; May 22, 1995; Federal Appellate Court

Narrative Opinion Summary

In this appellate case, the Contract Services Employee Trust and related parties contested the applicability of the Employee Retirement Income Security Act (ERISA) over certain provisions of the Oklahoma Workers' Compensation Act. The plaintiffs sought a declaratory judgment that Oklahoma's state law was preempted by ERISA or alternatively by the Labor Management Relations Act (LMRA). However, both the district court and subsequently the Tenth Circuit Court of Appeals concluded that ERISA does not preempt the workers' compensation provisions, citing consistent precedents from the First and Ninth Circuits, which addressed similar preemption issues in Maine and California. The plaintiffs also invoked LMRA Section 301 preemption, but the courts found this inapplicable as no interpretation of the collective bargaining agreement was necessary. Additionally, an argument presented under the Federal Arbitration Act was dismissed as it was not raised in the lower court. The district court's Rule 12(b)(6) dismissal for failure to state a claim was affirmed, emphasizing the lack of federal preemption over Oklahoma's workers' compensation law. This decision underscores the narrow scope of federal preemption in the context of state workers' compensation statutes, despite the involvement of ERISA-regulated benefit plans.

Legal Issues Addressed

ERISA Preemption of State Workers' Compensation Laws

Application: The court determined that ERISA does not preempt the Oklahoma Workers' Compensation Act, aligning with prior rulings from the First and Ninth Circuits regarding state workers' compensation laws in Maine and California.

Reasoning: The court evaluated and rejected the argument that ERISA preempts state workers' compensation laws, affirming the district court's ruling that Oklahoma's workers' compensation law is unaffected by ERISA, aligning with prior decisions from the First and Ninth Circuits.

Federal Arbitration Act and Preemption

Application: The court refused to consider the Federal Arbitration Act's preemption argument because it was not raised in the district court.

Reasoning: Additionally, the plaintiffs introduced a new argument regarding the Federal Arbitration Act, asserting it preempts Oklahoma law; however, this issue was not raised in the district court and thus could not be addressed on appeal.

LMRA Preemption and Collective Bargaining Agreements

Application: The court concluded that Section 301 of the LMRA does not preempt the Oklahoma Workers' Compensation Act as no interpretation of the collective bargaining agreement was required.

Reasoning: The plaintiffs also contended that the Oklahoma law is preempted under Section 301 of the LMRA, but the court agreed with the district court that this section only preempts state law when collective bargaining agreements are interpreted, which was not the case here.

Rule 12(b)(6) Motion to Dismiss

Application: The district court's dismissal of the complaint for failure to state a claim under Rule 12(b)(6) was upheld, as the plaintiffs' claims did not merit consideration for conversion to a summary judgment motion.

Reasoning: The district court had dismissed the complaint for failure to state a claim under Fed. R. Civ. P. 12(b)(6), and the court found no merit in the plaintiffs' claim that the motion to dismiss had been improperly converted to a summary judgment motion.