Midwest Motor Express, Inc. v. International Brotherhood of Teamsters

Midwest Motor Express, Inc. (Midwest) (plaintiff) was a trucking company with a facility in Roseville, Minnesota. International Brotherhood of Teamsters (the union) was the collective-bargaining representative of some of Midwest’s Roseville employees. In August of 1991, the union began a strike at Midwest’s Roseville facility. Midwest indicated that it would hire workers to permanently replace striking employees if economic conditions warranted, which was a practice that the federal National Labor Relations Act (NLRA) permitted but did not specifically protect from state regulation. Earlier in 1991, the Minnesota legislature had enacted the Striker Replacement Law, which made it an unfair labor practice and unlawful for employers to hire or threaten to hire permanent replacement workers during employee strikes. The law did not prohibit employers from hiring temporary replacement workers. The legislature enacted the law to address concerns about strike-related violence and misconduct and to ensure that strikes could be resolved peacefully. The law’s proponents in the legislature asserted that the law was necessary to restore the collective-bargaining balance between employers and employees and bring more stability to labor relations. Midwest brought an action against the union in Minnesota state court, seeking a declaration that the Striker Replacement Law was unconstitutional because it was preempted by the NLRA. The trial court considered Midwest’s arguments and issued a decision.