Supreme Court of the United States

Livadas v. Bradshaw, California Labor Commissioner

June 13, 1994512 U.S. 107

Summary

The Court unanimously held that federal labor law pre-empts the California Labor Commissioner's policy of refusing to enforce statutory wage-payment claims for employees covered by collective-bargaining agreements containing arbitration clauses. The policy impermissibly burdened employees' federally protected collective-bargaining rights. Section 301 of the Labor-Management Relations Act did not pre-empt Livadas's underlying penalty claim because it arose from independent state-law rights and required only consultation of an undisputed contractual wage rate. The Court further held that Livadas could seek relief under 42 U.S.C. § 1983 and reversed the Ninth Circuit's judgment. There were no separate opinions.

Holding

  • Federal pre-emption of the Commissioner's nonenforcement policy.. The NLRA pre-empts the policy of refusing to enforce otherwise applicable statutory wage-payment protections merely because an employee is covered by a collective-bargaining agreement containing an arbitration clause.
  • Section 301 pre-emption of Livadas's penalty claim.. Section 301 does not pre-empt Livadas's state-law late-payment penalty claim merely because calculating damages requires consulting the collective-bargaining agreement's undisputed wage rate.
  • Availability of relief under § 1983.. Livadas may bring her claim under § 1983 to remedy the Commissioner's abridgment of her NLRA rights.

Docket 92-1920

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