Avco Corp. v. Aero Lodge No. 735
Citation and Court
390 U.S. 557 (1968) — Supreme Court of the United States
Facts
Avco Corporation brought suit in Tennessee state court to enjoin a union from striking in alleged breach of a no-strike clause in a collective bargaining agreement. The union removed the case to federal court, arguing that the suit arose under § 301 of the Labor Management Relations Act (LMRA). The district court denied remand and issued the injunction; the Sixth Circuit affirmed jurisdiction.
Issue
Whether a state-law contract claim seeking to enforce a collective bargaining agreement arises under § 301 of the LMRA and is therefore subject to federal question jurisdiction and removal.
Holding
Yes. Section 301 of the LMRA completely preempts state-law claims for breach of a collective bargaining agreement, converting them into federal claims that support both federal question jurisdiction and removal.
Rule / Doctrine
Complete preemption under § 301 LMRA: where federal law so thoroughly occupies a field that any claim nominally arising under state law is actually a federal claim, the suit arises under federal law for jurisdictional purposes and is removable regardless of how the plaintiff pleads it.
Significance
Avco is the foundational case for the complete preemption doctrine. It establishes that artful pleading of a state-law claim cannot defeat federal jurisdiction when Congress has completely displaced state law in the field. The doctrine was later extended to ERISA in Metropolitan Life Ins. Co. v. Taylor (1987).