Golden State Transit Corp. v. City of Los Angeles
United States Supreme Court
493 U.S. 103 (1989)
- Written by Salina Kennedy, JD
Facts
The City of Los Angeles (city) (defendant) conditioned the renewal of Golden State Transit Corporation’s (Golden State) (plaintiff) taxi franchise on Golden State’s settlement of an ongoing labor dispute. Golden State challenged the city’s action in a lawsuit that was ultimately appealed to the United States Supreme Court. The Court held that the city had violated the National Labor Relations Act (NLRA), reasoning that the NLRA gives management the right to refuse to make concessions during collective bargaining and that the city’s imposition of a condition requiring Golden State to relinquish this right was preempted. The case was remanded to federal district court, and Golden State pursued a claim for damages under 42 U.S.C. § 1983, arguing that the city had violated Golden State’s federal right to refuse to make concessions during collective bargaining. The district court dismissed the claim, reasoning that the city’s conduct was preempted by the NLRA by operation of the Supremacy Clause of the United States Constitution, but that preemption did not give rise to a § 1983 claim. The court of appeals affirmed.
Rule of Law
Issue
Holding and Reasoning (Stevens, J.)
Dissent (Kennedy, J.)
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