Local 174, Teamsters v. Lucas Flour Co

In Local 174, Teamsters v. Lucas Flour Co., 369 U.S. 95 (1962), the Supreme Court held that, under section 301, a claim presenting a straightforward question of interpretation of a collective bargaining agreement must be decided by federal laws and rules. Thus, such a claim brought under state law is preempted by section 301. The Court reasoned that "the subject matter of 301(a) 'is peculiarly one that calls for uniform law.'" Id. at 103 (quoting Pa. R.R. Co. v. Pub. Serv. Comm'n of Pa., 250 U.S. 566 (1919)). It explained: The possibility that individual contract terms might have different meanings under state and federal law would inevitably exert a disruptive influence upon both the negotiation and administration of collective agreements. . . . The importance of the area which would be affected by separate systems of substantive law makes the need for a single body of federal law particularly compelling. The ordering and adjusting of competing interests through a process of free and voluntary collective bargaining is the keystone of the federal scheme to promote industrial peace. State law which frustrates the effort of Congress to stimulate the smooth functioning of that process thus strikes at the very core of federal labor policy. Id. at 103-04.