Verizon New England, Inc. v. R.I. Dep't of Labor & Training, No. 12-2398 (1st Cir. 2013)
Annotate this CaseVerizon New England, Inc. was a party to a collective bargaining agreement (CBA) with six electrical workers unions. After Verizon and the unions were unable to reach a new agreement before the CBA expired, the union members commenced a large-scale work stoppage. After the employees returned to work, several members of various unions employed by Verizon in Rhode Island applied for unemployment benefits. The Rhode Island Department of Labor and Training (RIDLT) denied unemployment benefits, but the RIDLT's board of review reversed. Verizon subsequently filed a federal court action against RIDLT and claimant union members, arguing that the board's decision to award unemployment benefits should not be enforced, as it was preempted by the National Labor Relations Act (NLRA). The district court dismissed the complaint, holding (1) the NLRA does not preempt a state's ability to provide strikers unemployment benefits; and (2) the action must be dismissed under the Younger absention doctrine. The First Circuit Court of Appeals affirmed but on the singular ground that the dismissal was warranted under the Younger absention doctrine.
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