The Supreme Court overturned the Court of Appeal`s decision to proceed with the Giants` request to convene. The Supreme Court concluded that, while Section 301 of the LMRA promotes political objectives to ensure consistency in the interpretation of ABCs and to obtain arbitration as a method of resolving CBA disputes, courts must also consider the interests of the state in monitoring material labour rights. The federal pre-purchase period under Section 301 cannot be deducted “lightly” because labour standards are traditionally left to the states. Seyfarth Synopsis: The California Supreme Court has held that the Labor Management Relations Act does not prejudge claims under the labour code when a defence asks little more than to refer to a collective agreement instead of actually interpreting the agreement. Melendez v San Francisco Baseball Associates LLC. Workers covered by a collective agreement that unquestionably provided “premium rates of pay for all overtime worked” under Section 514 of the California Labor Code are not entitled to additional daily overtime, as confirmed by a California Court of Appeal decision. Vranish v. Exxon Mobil Corp., No. B243443 (Cal. Ct.
App. 22.01.2014). Based on the clear language of Section 514, its legislative history and the instructions of the California Department of Industrial Relations, Division of Labor Standards Enforcement (“DLSE”), the Vranish Court rejected the workers` attempt to import daily overtime needs into their collective agreement and upheld a summary judgment favourable to the employer. Under Section 301 of the MRA (“Section 301”), federal courts have jurisdiction to adjudicate disputes arising from collective agreements. When an issue is both an agreement and a state right, determining the anticipation of state law requires the application of a two-part test. First, a court asks whether the remedy is a right that consists only of the collective agreement. If the law attempts to enforce a right created by the collective agreement itself, the right is anticipated. If this is not the case, the second step will be to determine whether the state`s law “essentially depends on the analysis of the agreement.” In other words, the claim of state law is not anticipated if it does not deal with the scope, meaning or application of the agreement. Security officials said they were employees who were temporarily fired at the end of each Giants home, at the end of the baseball season and at the end of other events in the park.
As a result, the security guards stated that they were entitled to their unpaid wages immediately after each relief, as requested in Section 201. The Giants countered that the security forces are not “intermittent” employees, but year-round employees who were not fired until they resigned or terminated, under the terms of a collective agreement (“CBA”) between the Giants and the union that represents the security guards. In addition, the Court found that, although Section 514 was ambiguous, the history of the legislation showed that Parliament did not envisage that “daily overtime requirements” would apply to workers in a qualified collective agreement.