Greene v. Dayton, No. 15-1441 (8th Cir. 2015)
Annotate this CasePlaintiffs, six homecare providers, filed suit challenging Minnesota's Individual Providers of Direct Support Services Representation Act, Minn. Stat. 179A.54, 179A.06. The Act allows homecare providers for Medicaid program participants to unionize. The court concluded that the district court properly dismissed plaintiffs' Supremacy Clause claim because the National Labor Relations Act (NLRA), 29 U.S.C. 152, does not preempt Minnesota's regulation of domestic service workers; plaintiffs' state preemption argument against the SEIU failed because even if the state laws conflict irreconcilably, the law passed most recently by the legislature controls and thus the Act trumps the older statute's definition of "employees;" the district court properly dismissed the providers' tortious interference claim against the state defendants because federal courts are unable to order state officials to conform their conduct to state law; and the district court properly dismissed plaintiffs' Contract Clause claims where plaintiffs did not have authority to negotiate compensation or benefits terms with program participants. Accordingly, the court affirmed the judgment.
Court Description: Murphy, Author, with Loken and Colloton, Circuit Judges] Civil case - Minnesota Individual Providers of Direct Services Representation Act. The Act permits homecare providers for Medicaid programs participants to unionize under the Public Employment Labor Relations Act. The providers' challenge to the Act as violative of the Supremacy Clause is rejected as the Act is not preempted by the National Labor Relations Act; tortious interference with contract claim was properly rejected as the defendant union's actions were justified as a matter of law under the Act, and a federal court could not order the state defendants to conform their conduct to state law; Contract Clause claims were properly rejected because the providers never had the authority to negotiate compensation or benefit terms with program participants.
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