Written by attorneys · grounded in primary & secondary sources — see below
A provision of the Labor Management Relations Act granting federal district courts jurisdiction over suits for violation of contracts between an employer and a labor organization in an industry affecting commerce. The statute authorizes courts to develop a body of federal common law to enforce collective bargaining agreements and to order specific performance of arbitration provisions.
Sources & Authorities
How it applies
Common Examples
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Employer Breach of CBA Arbitration Clause
Linden Logistics refused to arbitrate a grievance over overtime pay under its CBA with the union. The union sued in federal district court. The court exercised jurisdiction under Section 301 and ordered specific performance of the arbitration provision.
Union Suit for Contract Damages
Lola Langley’s union sued her former employer in federal court for violating a collective bargaining agreement’s wage provisions. The employer moved to dismiss. The court retained the case under Section 301 and applied federal common law to award damages.
Federal Common Law Governs CBA Interpretation
Lars Lindstrom’s union claimed the employer violated a seniority clause. The employer argued state contract law applied. The court held Section 301 required use of federal common law to interpret the agreement.
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Uniform Acts
Study Supplements
Specific Performance of Arbitration Award
A partner at Lakeshore Industries’ union obtained an arbitration award the employer refused to honor. The union sued under Section 301. The court enforced the award pursuant to federal common law developed under the statute.
Preemption of State Contract Claim
After Lexicon Media terminated an employee, the union filed a Section 301 action alleging breach of the CBA. The employer removed a parallel state suit. The federal court held Section 301 preempted the state claim.
Federal Labor Contract Enforcement
A union sued an employer in federal court for breaching a collective bargaining agreement's arbitration clause. The employer moved to dismiss for lack of jurisdiction. The court denied the motion because Section 301 both conferred jurisdiction and directed the court to fashion federal common law enforcing the agreement.
Textile Workers Union of Am. v. Lincoln Mills of Ala.353 U.S. 448 (1957)
Common questions
Frequently Asked
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Does LMRA § 301 merely confer jurisdiction or does it also authorize creation of federal substantive law?+
Section 301 both grants federal courts jurisdiction over suits for breach of collective bargaining agreements and directs them to fashion a body of federal common law for enforcement of those agreements, including specific performance of arbitration clauses.
Can a state-law tort claim that is intertwined with a collective bargaining agreement be brought in state court?+
A state-law claim that is inextricably intertwined with the meaning of a collective bargaining agreement is preempted by Section 301 and must be resolved under federal law in federal court.
What remedies are available under Section 301 for breach of a collective bargaining agreement?+
Federal courts may order specific performance of arbitration provisions and award damages or other relief consistent with the federal common law developed under Section 301.
353 U.S. 448 (1957)Labor Law
…should be specifically enforced. From the face of the Act it is apparent that § 301 (a) and § 301 (b) supplement one another. Section 301 (b) makes it possible for a labor organization, representing employees in an industry affecting commerce, to sue and be sued as an entity in the federal courts. Section 301 (b) in other…