486 U.S. 399 (U.S. 1988)
Lingle v. Norge Division of Magic Chef is a cornerstone Supreme Court decision delineating the boundary between federal labor-contract preemption under §301 of the Labor Management Relations Act (LMRA) and state-law workplace protections.
Does LMRA §301 preempt a state-law retaliatory discharge claim when the claim can be resolved without interpreting the terms of a collective bargaining agreement, even though the facts overlap with a CBA grievance and arbitration concerning just cause?
Section 301 of the LMRA preempts state-law claims that are substantially dependent upon analysis of the terms of a collective bargaining agreement or that require interpreting the agreement. A state-law claim is not preempted if it confers nonnegotiable rights independent of the CBA and can be resolved by purely factual inquiries without construing CBA provisions. Mere factual overlap with matters addressed in a grievance/arbitration, or the need to consult (but not interpret) the CBA, does not trigger §301 preemption.
No. An Illinois tort action for retaliatory discharge based on filing a workers' compensation claim is not preempted by LMRA §301 because its elements can be adjudicated without interpreting the CBA. The Supreme Court reversed the judgment of the Seventh Circuit and remanded.
Lingle is the leading case articulating the modern §301 preemption test: ask whether the state claim's elements can be resolved without interpreting a CBA. It preserves state-law workplace protections for unionized employees, including public-policy torts and statutory rights, when those claims are independent of contract interpretation. The decision is frequently paired with Allis-Chalmers v. Lueck and later cases such as Hawaiian Airlines v. Norris to teach the difference between factual overlap (not preempted) and interpretive dependence (preempted). For students and practitioners, Lingle offers a practical roadmap for pleading and litigating around §301 preemption and understanding the coexistence of arbitration remedies with independent state-law causes of action.