Boldt v. Northern States Power Co., No. 17-2231 (8th Cir. 2018)Annotate this Case
At issue in this case was whether the Labor Management Relations Act completely preempts a Minnesota Human Rights Act claim for disability discrimination brought by a former employee of a nuclear power plant. The Eighth Circuit reversed the district court's denial of remand to state court and grant of judgment on the pleadings to the employer, holding that the employee's claim could not be resolved without interpreting a collective-bargaining agreement. The court held that section 301 of the Act completely preempted plaintiff's disability discrimination claim under the Minnesota Human Rights Act; the district court had jurisdiction over the removed matter; and the judgment on the pleadings was properly granted because the section 301 claim was time-barred.