By Rick Gautschi
In Watson v. Providence St. Peter Hospital, 193 LRRM 3056, No. C12-5352 BHS, July 18, 2012, W.D. Wa., during March 2012, Carroll Watson (Ms. Watson) filed a complaint in Thurston County, WA, Superior Court against Providence St. Peter Hospital and several agents of the hospital (Providence St. Peter). Although she set forth eight separate claims in the complaint, all eight derived from her allegation that the defendants had denied her meal and rest breaks to which she was entitled. She contended that the denial meant that for extended periods, she had to continue working while she was seated in her own human waste. As a result of doing so, she suffered injuries for which she sought redress. Soon after Ms. Watson filed the complaint, Providence St. Peter, citing the Labor Management Relations Act’s (LMRA’s) provision that confers original jurisdiction over claims that arise out of a collective bargaining agreement (CBA), removed the case to federal court. Subsequently, Ms. Watson moved to have the federal court remand the case back to Thurston County Superior Court on the ground that her claims did not require interpretation of provisions in a CBA.
In assessing Ms. Watson’s motion, the federal court (Court) noted that LMRA preemption bars a plaintiff from litigating claims involving alleged breaches of a CBA in a state court. To determine whether Ms. Watson’s claims required the interpretation of the CBA, the Court looked beyond the face of her complaint.
The Court reasoned that three of her claims came within the heading of breach of the CBA: wrongful termination, unreasonable denial of medical coverage, and failure to protect her interest by denying medical coverage and time off. Resolving those claims would necessarily require interpretation of the CBA.
Consequently, the LMRA made the Court the proper forum for resolving those claims. Because her other five claims did not require an interpretation of the CBA, the LMRA did not dictate that a federal court was the proper forum for resolving those claims. Regardless, because the Court found the five claims to be intertwined with the other three claims, pursuant to a federal statute it decided to exercise supplemental jurisdiction over them. Accordingly, the Court denied Ms. Watson’s motion to remand in its entirety.
