Legal Definitions - Lingle test

The Lingle test is a legal standard used in labor law to determine whether a union member's claim against their employer, brought under state law, is "preempted" by federal labor law, specifically the Labor–Management Relations Act (LMRA).

In simpler terms, preemption means that federal law takes precedence over state law, preventing a state court from hearing a particular case. The core principle of the Lingle test is straightforward: if a state-law claim can be resolved without needing to interpret the terms of the collective-bargaining agreement (CBA) between the union and the employer, then the claim is not preempted, and the state court can hear it. However, if resolving the state-law claim requires a court to analyze or interpret the specific provisions of the CBA, then it is preempted, and the claim must be handled under federal labor law procedures.

Here are some examples to illustrate how the Lingle test applies:

• Example 1: State Anti-Discrimination Claim (Not Preempted)

  Imagine a unionized employee who believes they were fired because of their age, in violation of a state's anti-discrimination law. While the collective-bargaining agreement (CBA) might contain a general "just cause" provision for termination, the employee's state-law claim focuses on the employer's discriminatory *motive* as prohibited by state statute. To resolve this claim, a court would primarily examine evidence of discriminatory intent and the state law's requirements, rather than interpreting the specific language of the CBA's "just cause" clause. Since the state-law claim can be resolved independently of the CBA's interpretation, it would likely *not* be preempted by federal law under the Lingle test.

• Example 2: Dispute Over Disciplinary Procedures (Preempted)

  Consider a union member who is suspended from work and files a state-law claim for "wrongful discipline," arguing that the employer failed to follow the specific progressive disciplinary steps outlined in their collective-bargaining agreement. To determine if the discipline was "wrongful" according to the employee's claim, a court would be required to closely examine and interpret the CBA's detailed provisions regarding warnings, suspensions, and other disciplinary actions. Because resolving this state-law claim would necessitate interpreting the CBA, it would likely be preempted by federal labor law under the Lingle test.

• Example 3: State Wage and Hour Violation (Not Preempted)

  Suppose a unionized employee claims their employer failed to pay them for all hours worked, in violation of the state's minimum wage and overtime laws. Even if the collective-bargaining agreement specifies wage rates, the employee's claim is based on a fundamental right to be paid for time worked as established by state statute, independent of the CBA's specific wage scales. The court would primarily look at state law requirements and actual hours worked, not necessarily interpret the CBA's wage clauses to resolve the core dispute. Therefore, this state-law claim would likely *not* be preempted under the Lingle test.