interpretation or application of agreements about "pay, rules, or working conditions."[1]
There is an exception to this broad preemption, though, for independent state rights. Some exceptions are obvious, such as when the state right does not concern "pay, rules or working conditions." But there are plenty of possible claims that arguably overlap both collective bargaining agreement provisions and state law. The Supreme Court appears to have evolved from the broadest possible preemption rule toward a more qualified rule, at least with respect to independent statecreated rights.
The seminal preemption case, establishing the breadth of Railway Labor Act preemption, is Teamsters v. Lucas Flour Co.[2] It holds that federal labor law must be paramount under the supremacy clause in areas covered by the federal statute, to avoid inconsistent state law interpretations under state contract law of collective bargaining agreements.[3]
Allis-Chalmers Corp. v. Lueck holds that an apparently independent state tort unrelated to working conditions, bad faith denial of insurance coverage, was nevertheless preempted, because the bad faith claim was "inextricably intertwined" with the group health policy established pursuant to the collective bargaining agreement.[4]Lueck
