Overview
Major League Baseball today moved to dismiss Alex Rodriguez’s suit accusing it of tortuously interfering with his Yankees contract and potential endorsement deals. The League argues that his suit is preempted by Section 301 of the Labor Management Relations Act, 29 U.S.C. § 185(a), because the allegations are inextricably intertwined with collective bargaining arrangements:
Section 301 completely preempts both of Plaintiff’s claims because, as pled, they are inextricably intertwined with – indeed, utterly dependent upon – interpretation of the Basic Agreement and the Joint Drug Agreement. In fact, the Complaint is littered with allegations making it evident that the essence of his claims consists of MLB’s purported violations of its collectively-bargained obligations. In particular, Plaintiff states that Defendants: •“ignored the procedures set forth in baseball’s collectively-bargained labor agreements”; •“circumvent[ed] the procedures set forth in the collectively-bargained agreements governing the relationship between MLB and the [MLBPA]”; •“violated the confidentiality provisions of the collectively-bargained agreements”; •took steps “outside the labor process to collect evidence”; and •“trampl[ed] Mr. Rodriguez’s collectively-bargained rights.” Of the 95 paragraphs in the Complaint, 43 contain allegations that reference the collectively-bargained agreements or matters covered by those agreements at issue in the pending arbitration.Mr. Rodriguez’s motion to remand counters that his suit is fundamentally a tort action:
Instead, the Complaint alleges that Defendants used wrongful means to destroy Mr. Rodriguez's reputation and career, thereby tortiously interfering with his current and potential business relationships. This Court does not need to interpret the provisions of the Agreements to adjudicate any of the elements of Mr. Rodriguez's "claims. The mere fact the Complaint pleads facts that can also serve as the basis of a grievance under the Agreements is not a basis for LMRA preemption. Similarly, the LMRA does not preempt claims where the Agreements are only used as a defense to the state law claim. Here, the only possible relevance the Agreements may have to this litigation is to Defendants' potential defenses, and not to Mr. Rodriguez's affirmative case. Thus, Defendants cannot meet their burden of demonstrating that a valid basis of subject matter jurisdiction exists over this dispute.Our prior post on the case is here.
