Supreme Court of the United States

Association of Westinghouse Salaried Employees v. Westinghouse Electric Corp.

March 28, 1955348 U.S. 437

Summary

The Court affirmed dismissal of the union's suit because § 301 did not confer federal jurisdiction over a union action seeking accrued wages owed to individual employees under their separate employment contracts. The Court rejected the view that § 301 created a body of federal substantive contract law and construed the provision, in light of its text and legislative history, as not reaching this type of wage claim. Justice Reed and Chief Justice Warren concurred on narrower or different grounds, while Justice Douglas, joined by Justice Black, would have allowed the union to sue to enforce the collective bargaining agreement.

Holding

  • Whether § 301 creates substantive federal contract law or primarily supplies federal jurisdiction and procedural rules. Section 301 is a jurisdictional and procedural provision and does not authorize federal courts to create a general body of substantive federal law governing collective bargaining agreements.
  • Whether § 301 confers jurisdiction over the union's suit for accrued employee wages. Section 301 does not confer federal jurisdiction over this suit because the union sought to enforce employees' uniquely personal rights to accrued wages rather than a breach of an undertaking between the employer and the union.
  • Whether the alleged wage obligation arose from the collective bargaining agreement or separate employment contracts. The alleged duty to pay the employees' wages arose from separate hiring contracts between the employer and each employee, not from a contract between the employer and the union within the meaning of § 301.

Docket 51

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