[DOWNLOAD] "White v. National Steel Corp." by United States Court of Appeals for the Fourth Circuit ~ Book PDF Kindle ePub Free
eBook details
- Title: White v. National Steel Corp.
- Author : United States Court of Appeals for the Fourth Circuit
- Release Date : January 03, 1991
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 77 KB
Description
WILKINSON, Circuit Judge This case concerns the proper scope of federal and state regulation of employment relationships. The issues arise from layoffs of steel workers which occurred in 1982 at the Weirton Division of the National Steel Corporation in West Virginia. The plaintiffs are former union members who accepted management positions after National Steel allegedly made them promises of job security, including the right to return to their former positions in bargaining units. They maintain that their layoffs from salaried management positions constituted breaches of their individual employment contracts which are actionable under state law and that National Steel fraudulently induced them into accepting management positions. National Steel responds that plaintiffs' claims are actually for breaches of collective bargaining agreements and must be pursued under § 301 of the Labor-Management Relations Act, 29 U.S.C. § 185 or dismissed as preempted. Furthermore, National argues that subsequent changes in the governing collective bargaining agreements prohibited plaintiffs' returning to their former bargaining units and that the individual contracts must yield as preempted. We hold that plaintiffs' claims are primarily grounded in individual employment contracts and not in collective bargaining agreements. Although a subsequent collective bargaining agreement does preempt any specific performance of individual contracts that plaintiffs might seek, damages are still available under state law theories. We additionally hold that summary judgment should have been granted to National Steel on plaintiffs' state law claims for fraud, and remand for application of the proper evidentiary standard to plaintiffs' breach of contract claims.