## Facts

- Golden State Transit Corporation operated taxicabs in Los Angeles under a city franchise.
- During a labor dispute with its drivers’ union, Los Angeles refused to renew Golden State’s franchise unless the dispute was settled.
- In prior litigation, the Supreme Court held the City’s condition was preempted by the NLRA because it interfered with collective-bargaining “economic weapons” reserved to the free play of economic forces.
- On remand, the district court ordered the City to reinstate the franchise but denied Golden State compensatory damages under 42 U.S.C. § 1983.
- The district court reasoned that (1) the Supremacy Clause does not itself create enforceable rights under § 1983 and (2) the NLRA’s enforcement scheme impliedly foreclosed a § 1983 damages remedy.
- The Ninth Circuit affirmed the denial of § 1983 damages, and Golden State sought Supreme Court review.

## Issues

1. Whether the Supremacy Clause, by itself, creates “rights” enforceable under 42 U.S.C. § 1983 for conduct preempted by federal law.
2. Whether the NLRA confers federal rights enforceable under § 1983 when a municipality interferes with the federally protected use of economic weapons in collective bargaining.
3. Whether the NLRA’s enforcement scheme implicitly precludes a § 1983 damages action for state or local interference with NLRA-protected rights.

## Decision

- The Supreme Court reversed and remanded.
- The Court held that the Supremacy Clause does not, of its own force, create rights enforceable under § 1983.
- The Court held that the NLRA confers rights on parties to collective bargaining to use economic weapons free from state or municipal interference, and those rights are enforceable under § 1983.
- The Court held that § 1983 was not foreclosed because the NLRA provides no mechanism to remedy the type of state interference at issue.

## Legal Principles

- The Supremacy Clause establishes federal-law priority over conflicting state law but is not an independent source of rights enforceable under § 1983.
- A federal statutory “right” enforceable under § 1983 may be implicit in a statute’s structure and operation, not only express in statutory text.
- Under the NLRA’s allocation of regulatory space, parties have a federally protected right to deploy lawful economic weapons in collective bargaining without state or municipal interference in areas Congress left unregulated.
- A § 1983 remedy is displaced only when Congress intended to foreclose it, which may be shown by a comprehensive remedial scheme that meaningfully addresses the specific violation; the NLRA’s scheme did not address municipal interference of this kind.

## Conclusion

The Court allowed a § 1983 damages action against Los Angeles because the City’s preempted conduct infringed federally protected NLRA rights, while clarifying that preemption under the Supremacy Clause alone does not create a § 1983 cause of action.


Golden State Transit Corp. v. City of Los Angeles, 493 U.S. 103 (1989)