Melendez v. San Francisco Baseball Associates LLCAnnotate this Case
The Supreme Court reversed the judgment of the court of appeals concluding that this lawsuit brought by security guards at Oracle Park (the former AT&T Park in San Francisco) against San Francisco Baseball Associates LLC (the Giants) alleging a violation of Cal. Lab. Code 201, subd. (a) was preempted under federal law and must be submitted to arbitration, holding that the trial court correctly denied the Giants' motion to compel arbitration.
In this action, the guards claimed that they were discharged after every Giants homestead, at the end of the baseball season, and after other events at the park, and that they were entitled under section 201 to receive their unpaid wages immediately after each discharge. The Giants moved to compel arbitration, arguing that this action was preempted by the Labor Management Relations Act because the controversy required interpretation of the collective bargaining agreement (CBA) entered into between the parties. The trial court denied the motion. The court of appeal reversed. The Supreme Court reversed, holding (1) while the CBA may be relevant to this lawsuit, the dispute turned on the meaning of "discharge" under section 201 rather than an interpretation of the CBA itself; and (2) therefore, the lawsuit was not preempted, and state courts may decide it on the merits.