In Friday v. Hughes Aircraft Co. (1986) 188 Cal.App.3d 117, the plaintiff was subject to a collective bargaining agreement that contained mandatory grievance and arbitration procedures for resolving employee disputes. The employer obtained summary judgment on the ground that the plaintiff's common law claims for wrongful termination and intentional infliction of emotional distress were preempted by section 301 of the Labor Management Relations Act (LMRA). The appellate court affirmed the summary judgment based on federal decisions regarding the preemption of common law claims by section 301. (Id. at pp. 121-125.) The appellate court's determination in Friday that the plaintiff's common law claims were preempted by section 301 is consistent with the "general rule . . . that an employee covered by a collective bargaining agreement providing for arbitration of grievances may not maintain a civil action for damages in the case of an alleged breach of the agreement, but must instead look to the union for a remedy provided by the contractual grievance procedure. In cases where a collective bargaining agreement provides procedures for settling disputes, those become the exclusive remedy of the employee and the courts have no jurisdiction to review the merits of the employee's claim. Consequently, if a party avoids the contractual grievance procedure by suing before invoking the grievance mechanism, the claim must be dismissed."