Amalgamated Ass'n of Street, Elec. Ry. and Motor Coach Employees of Am. v. Lockridge
In Amalgamated Ass'n of Street, Elec. Ry. and Motor Coach Employees of Am. v. Lockridge, 403 U.S. 274, 91 S.Ct. 1909, 29 L.Ed.2d 473 (1971), the Supreme Court applied the Garmon preemption doctrine in the context of a state judgment based on a breach of contract theory and on facts that arguably constituted a violation of NLRA Secs. 8(b)(2) and (a)(1), (3). Id. at 293, 91 S.Ct. at 1921.
It noted that concurrent state court and federal administrative jurisdiction over such conduct bristled with potential conflicts between rules of substantive law, methods of administering that law, and remedies for its violation. Id. at 287-88, 91 S.Ct. at 1918.