Legal Definitions - complete-preemption doctrine

The complete-preemption doctrine is a powerful legal principle that allows certain federal laws to be so extraordinarily comprehensive and dominant in a particular area that they effectively transform a lawsuit based on state law into a federal lawsuit. This transformation occurs even if the original complaint filed in state court only mentions state-law claims, without any reference to federal law.

When a federal statute completely preempts a field, any state-law claim falling within that field is automatically recharacterized as a federal claim. This is significant because it grants federal courtsjurisdiction over the case, meaning the lawsuit can be moved from state court to federal court, even if the plaintiff initially chose to sue under state law.

• Example 1: Employee Retirement Benefits

  Imagine an individual sues their former employer in state court, claiming the employer failed to pay out their promised retirement benefits. The individual's lawsuit is based on a state-law claim, such as breach of contract or promissory estoppel. However, if the retirement plan is an employee benefit plan governed by the Employee Retirement Income Security Act (ERISA), a comprehensive federal law, the complete-preemption doctrine would likely apply. Even though the plaintiff only cited state law, ERISA's extensive regulation of employee benefit plans is so dominant that the state-law claim is automatically reinterpreted as a federal claim under ERISA. This allows the employer to "remove" the case from state court to federal court, as it is now considered a federal question.

• Example 2: Collective Bargaining Agreements

  Consider a scenario where a unionized employee sues their employer in state court, alleging that the employer violated a provision of their collective bargaining agreement (a contract negotiated between the union and the company). The employee might frame their lawsuit as a state-law breach of contract claim. However, Section 301 of the Labor Management Relations Act (LMRA) is a federal statute that completely preempts state-law claims requiring the interpretation of collective bargaining agreements. Because the federal LMRA comprehensively governs disputes arising from these agreements, the employee's state-law contract claim is automatically reclassified as a federal claim under the LMRA. This means the employer can move the case to federal court, despite the employee's initial reliance on state contract law.