Williams v. National Football League

The NFL's (defendant) collective bargaining agreement (CBA) with the players' union incorporated an anti-doping policy banning masking agents like diuretics and holding players strictly responsible for what was in their bodies. Five players, including Pat Williams (plaintiff), tested positive for the diuretic bumetanide, an unlisted ingredient in the supplement StarCaps, and were suspended four games without pay; the suspensions were upheld internally. The players sued in Minnesota state court to vacate the decision, raising claims under Minnesota's Drug and Alcohol Testing in the Workplace Act (DATWA) and other state-law theories. The NFL removed to federal court, which enjoined the suspensions and held the state claims not preempted by LMRA section 301; both sides appealed.

Whether LMRA section 301 preempts state-law drug-testing claims that are substantially dependent upon interpretation of a collective bargaining agreement.