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15 Washington opinions name it 2 courts 1986–2023 2 in the last five years
The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Wisconsin Department of Industry, Labor & Human Relations v. Gould Inc.green2 sentences2023Moreover, “[t]he NLRA does indeed preempt state or local laws that create supplemental sanctions for violations of the NLRA. ‘[T]he Garmon rule prevents States . . . from providing their own regulatory or judicial remedies for conduct prohibited or arguably prohibited by the Act.’” Filo Foods, LLC v. City of SeaTac, 183 Wn.2d 770, 801-02 , 357 P.3d 1040 (2015) (quoting Wis. Dep’t of Indus., Labor & Human Relations v. Gould Inc., 475 U.S. 282, 286 , 106 S. Ct. 1057 , 89 L. Ed. 2d 223 (1986)). 19 As the district court noted, however, the Unions’ claims under state law are distinct from the claim 2023Moreover, “[t]he NLRA does indeed preempt state or local laws that create supplemental sanctions for violations of the NLRA. ‘[T]he Garmon rule prevents States . . . from providing their own regulatory or judicial remedies for conduct prohibited or arguably prohibited by the Act.’” Filo Foods, LLC v. City of SeaTac, 183 Wn.2d 770, 801-02 , 357 P.3d 1040 (2015) (quoting Wis. Dep’t of Indus., Labor & Human Relations v. Gould Inc., 475 U.S. 282, 286 , 106 S. Ct. 1057 , 89 L. Ed. 2d 223 (1986)). 19 As the district court noted, however, the Unions’ claims under state law are distinct from the claim | 2 | 5 |
Farmer v. United Brotherhood of Carpenters & Joiners of America, Local 25green2 sentences1994Farmer, 430 U.S. at 298, 300 . 1994Farmer, 430 U.S. at 298, 300 . | 1 | 2 |
Beaman v. Yakima Valley Disposal, Inc.green2 sentences1993Lumber Prod., 775 F.2d at 1047-48 (quoting Garmon, 359 U.S. at 245 ); accord, Beaman, 116 Wn.2d at 704 . 1993Lumber Prod., 775 F.2d at 1047-48 (quoting Garmon, 359 U.S. at 245 ); accord, Beaman, 116 Wn.2d at 704 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Hume v. American Disposal Co.
green
2 sentences2001"The Garmon doctrine operates to preempt claims based upon a state law which attempts to regulate conduct that is arguably either prohibited or protected by the National Labor Relations Act." Hume, 124 Wash.2d at 662 , 880 P.2d 988 (citing San Diego Bldg. 2001"The Garmon doctrine operates to preempt claims based upon a state law which attempts to regulate conduct that is arguably either prohibited or protected by the National Labor Relations Act." Hume, 124 Wash.2d at 662 , 880 P.2d 988 (citing San Diego Bldg. | 6 | 2000–2010 |
San Diego Building Trades Council v. Garmon
green
2 sentences1994The Supreme Court has reinforced this structure by developing the Garmon rule that "[w]hen an activity is arguably subject to § 7 or § 8 of the Act, the States as well as the federal courts must defer to the exclusive competence of the National Labor Relations Board if the danger of state interference with national policy is to be averted." Garmon, 359 U.S. at 245 . 1994The Supreme Court has reinforced this structure by developing the Garmon rule that "[w]hen an activity is arguably subject to § 7 or § 8 of the Act, the States as well as the federal courts must defer to the exclusive competence of the National Labor Relations Board if the danger of state interference with national policy is to be averted." Garmon, 359 U.S. at 245 . | 5 | 1991–2001 |
Inter-Modal Rail Employees Ass'n v. Burlington Northern & Santa Fe Railway Co.
green
2 sentences2001Fluor argues that cases applying the Garmon exception are based on state statutes and involve only private sector workplaces, citing Hume; Delahunty; Inter-Modal Rail Employees Ass’n v. Burlington N. & Santa Fe Ry., 73 Cal. App. 4th 918 , 87 Cal. Rptr. 2d 60 (1999); and Paige v. Henry J. 2001Fluor argues that cases applying the Garmon exception are based on state statutes and involve only private sector workplaces, citing Hume; Delahunty; Inter-Modal Rail Employees Ass’n v. Burlington N. & Santa Fe Ry., 73 Cal. App. 4th 918 , 87 Cal. Rptr. 2d 60 (1999); and Paige v. Henry J. | 2 | 2001–2001 |
Filo Foods, LLC v. City of SeaTac
green
2 sentences2023Moreover, “[t]he NLRA does indeed preempt state or local laws that create supplemental sanctions for violations of the NLRA. ‘[T]he Garmon rule prevents States . . . from providing their own regulatory or judicial remedies for conduct prohibited or arguably prohibited by the Act.’” Filo Foods, LLC v. City of SeaTac, 183 Wn.2d 770, 801-02 , 357 P.3d 1040 (2015) (quoting Wis. Dep’t of Indus., Labor & Human Relations v. Gould Inc., 475 U.S. 282, 286 , 106 S. Ct. 1057 , 89 L. Ed. 2d 223 (1986)). 19 As the district court noted, however, the Unions’ claims under state law are distinct from the claim 2023Moreover, “[t]he NLRA does indeed preempt state or local laws that create supplemental sanctions for violations of the NLRA. ‘[T]he Garmon rule prevents States . . . from providing their own regulatory or judicial remedies for conduct prohibited or arguably prohibited by the Act.’” Filo Foods, LLC v. City of SeaTac, 183 Wn.2d 770, 801-02 , 357 P.3d 1040 (2015) (quoting Wis. Dep’t of Indus., Labor & Human Relations v. Gould Inc., 475 U.S. 282, 286 , 106 S. Ct. 1057 , 89 L. Ed. 2d 223 (1986)). 19 As the district court noted, however, the Unions’ claims under state law are distinct from the claim | 1 | 2023–2023 |
Paige v. Henry J. Kaiser Co.
green
2 sentences2001Kaiser Co., 826 F.2d 857 (9th Cir. 1987). 2001Kaiser Co., 826 F.2d 857 (9th Cir. 1987). | 1 | 2001–2001 |
Lumber Production Industrial Workers Local 1054 v. West Coast Industrial Relations Ass'n
green
2 sentences1993Lumber Prod., 775 F.2d at 1047-48 (quoting Garmon, 359 U.S. at 245 ); accord, Beaman, 116 Wn.2d at 704 . 1993Lumber Prod., 775 F.2d at 1047-48 (quoting Garmon, 359 U.S. at 245 ); accord, Beaman, 116 Wn.2d at 704 . | 1 | 1993–1993 |
Lodge 76, International Ass'n of MacHinists & Aerospace Workers v. Wisconsin Employment Relations Commission
green
2 sentences1991Relations Comm'n, 427 U.S. 132 , 49 L.Ed.2d 396 , 96 S.Ct. 2548 (1976); and the Garmon doctrine, found in San Diego Bldg. 1991Relations Comm'n, 427 U.S. 132 , 49 L.Ed.2d 396 , 96 S.Ct. 2548 (1976); and the Garmon doctrine, found in San Diego Bldg. | 1 | 1991–1991 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.