In a decision issued by the United States District Court for the District of Rhode Island on March 29, 2007, the Court held that a former faculty member at Roger Williams University was prohibited from bringing a lawsuit against a University dean for allegedly intentionally interfering with his contractual relationship with the University. Morgan, Brown & Joy successfully represented the University dean in the matter.
In Alfieri v. Koelle, Civil Action No. 06-510 ML, a faculty member who had been dismissed from Roger Williams University brought a civil complaint against a University dean who was involved in the review of his performance. In his complaint filed with the Court, the faculty member alleged that the dean had intentionally and wrongly interfered with his “contract” with the University. The faculty member worked at the University pursuant to a collective bargaining agreement between the faculty union and the University, and this was the “contract” with which the dean had allegedly interfered.
Morgan, Brown & Joy argued on behalf of the dean that the faculty member’s state law claim of intentional interference with contract was totally preempted by Federal labor law. The Court concurred and held that pursuant to Section 301 of the Labor Management Relations Act (LMRA), 29 U.S.C. §185, the faculty member’s sole remedy was to pursue the grievance and arbitration procedure pursuant to the collective bargaining agreement. (Indeed, the faculty member had initiated that process with his union, and the arbitration hearings assessing his claim of breach of the collective bargaining agreement were underway).
The Court found that Section 301 of the LMRA mandated dismissal of the case because resolution of the faculty member’s claim would require the Court (1) to determine whether the collective bargaining agreement had been breached or (2) to, at least, interpret the meaning of provisions of the collective bargaining agreement. The Court determined that such disputes were entirely a matter of Federal labor law and that state law claims alleging a violation of a collective bargaining agreement or requiring an interpretation of a collective bargaining agreement cannot survive. In the end, a union’s member’s grievance can only proceed under the procedures set forth in the collective bargaining agreement. The case was therefore dismissed with prejudice.