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Belknap, Inc. v. Hale
United States Supreme Court
463 U.S. 491 (1983)
When negotiations over a new collective-bargaining agreement (CBA) with Belknap, Inc. (defendant) reached an impasse, about 400 unionized workers struck. The same day, Belknap unilaterally granted a wage increase for those who stayed on the job. Belknap advertised for workers to “permanently replace” strikers, and each replacement signed a statement acknowledging employment as a “permanent replacement.” After the union filed unfair-labor-practice charges based on the unilateral wage increase, Belknap filed its own charges against the union and distributed a letter reassuring replacements they would remain permanent. When the National Labor Relations Board (NLRB) issued a complaint against Belknap, it again assured replacements their employment would remain unchanged. But the union and Belknap settled, agreeing to dismiss the charges and reinstate strikers, and Belknap laid off the replacements. Twelve laid-off replacements including Hale (plaintiffs) sued Belknap in Kentucky state court for misrepresentation and breach of contract. The court granted Belknap summary judgment, reasoning that the National Labor Relations Act (NLRA) preempted the state-law claims. The appellate court reversed, and the Supreme Court granted review.
Rule of Law
Holding and Reasoning (White, J.)
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