Lingle v. Norge Division of Magic Chef, Inc.
United States Supreme Court
486 U.S. 399 (1988)
Jonna Lingle (plaintiff) filed a worker's compensation claim for a workplace injury, and Norge Division of Magic Chef, Inc. (defendant) fired her days later for allegedly filing a false claim; her union grieved the discharge under a collective-bargaining agreement barring termination without just cause, and an arbitrator ultimately ruled in Lingle's favor. Before that arbitration concluded, Lingle separately sued Norge in Illinois state court for retaliatory discharge; Norge removed to federal court and moved to dismiss, arguing the Labor Management Relations Act (LMRA) preempted her state-law tort claim. The district court dismissed, and the court of appeals affirmed, before the Supreme Court granted certiorari.
Whether an employee's state-tort claim for retaliatory discharge is preempted by the Labor Management Relations Act if the application of the state law does not require the interpretation of a collective-bargaining agreement.