November 10, 2013

Caterpillar Inc. v. Williams | Case Brief - 482 U.S. 386, 107 S.Ct. 2425 (1987) - Supreme Court of the United States

FACTS: Respondents had all worked for Caterpillar Inc. in San Leandro for 3-15 years.  During the course of their employment thay were repeatedly assured that they would always have employment opportunities with Caterpillar.  Over time each became either a managerial or weekly salaried employee outside the coverage of collective-bargaining agreement.  They claim the repeated promises created a "total employment agreement wholly independent of the collective-bargaining agreement pertaining to hourly employees."  At one point Caterpillar downgraded them to hourly and said those assignments were temporary.

Respondents filed suit in state court claiming that the contract with Caterpillar was breached without regard to the individual employment contracts.  Caterpillar then went to remove the action to federal court arguing that removal was proper because any individual contracts in the end were merged with the collective-bargaining rights which allowed federal jurisdiction under section 301 o
Labor Management Relations Act (LMRA) The District Court dismissed when defendants refused to amend their complaints.

Court of Appeals for the 9th Circuit reversed.

ISSUE: Can defendant change basis of plaintiff's complaint?



First, Caterpillar wants to use a federal defense as the basis for removal.  But one cannot remove to federal court based on federal defense.  "Only state-court actions that originally could have been filed in federal court may be removed to federal court by the defendant"

Without diversity of citizenship, federal jurisdiction is required.  That is in turn governed by the well-pleaded complaint rule which "provides that federal jurisdiction exists only when a federal question is presented on the face of the plaintiffs properly pleaded complaint."

Caterpillar also claims that section 301 LMRA preempts the well-pleaded complaint rule.  Overruled because plaintiffs did not bring complaint in on basis of collective-bargaining which is basis for section 301.

Next Caterpillar claims individual contracts were merged away when the employees went back to work hour and therefore at the collective-bargaining status.  Plaintiff is however permitted to assert individual rights outside of a state claim.  Furthermore its basing its attempts to remove on facts not alleged in the complaint.

Finally, presence of federal question in the defense does not override plaintiff's mastery of the complaint.