## Facts

- Midwest Motor Express, Inc. (Midwest) operated a trucking facility in Roseville, Minnesota.
- The International Brotherhood of Teamsters (the union) served as the collective-bargaining representative for certain Midwest employees at the Roseville facility.
- In August 1991, after contract negotiations failed, the union began an economic strike at the Roseville facility.
- Midwest stated that it would hire replacement workers and that it would hire workers as *permanent* replacements if business conditions warranted.
- Earlier in 1991, Minnesota enacted a “Striker Replacement Law,” codified at Minn. Stat. § 179.12(9) (Supp. 1991), making it an unfair labor practice and unlawful for an employer to hire or threaten to hire *permanent* replacement workers during a strike.
- The Minnesota law allowed employers to hire *temporary* strike replacements.
- Supporters of the Minnesota law cited strike-related violence and misconduct, and a desire for more stable labor relations, as reasons for restricting permanent replacement hiring during strikes.
- Midwest filed an action in Minnesota state district court against the union seeking a declaratory judgment that the Striker Replacement Law was unconstitutional because it was preempted by the National Labor Relations Act (NLRA) and therefore invalid under the Supremacy Clause.
- The district court considered Midwest’s federal preemption arguments and issued its decision.

## Issues

1. Whether Minn. Stat. § 179.12(9), which bars employers from hiring or threatening to hire permanent strike replacements (while permitting temporary replacements), is preempted by the NLRA and unconstitutional under the Supremacy Clause.
2. Whether a declaratory-judgment challenge was justiciable during an ongoing strike where Midwest had announced an intention to use permanent replacements if conditions warranted.

## Decision

- The district court ruled against Midwest and upheld the Minnesota Striker Replacement Law.
- The court held the statute was not preempted by the NLRA and was constitutional under the Supremacy Clause.
- The court allowed declaratory relief because Midwest’s stated intent to use permanent replacements presented an actual dispute over the statute’s validity and application.

## Legal Principles

- Federal labor-law preemption can bar state regulation of labor relations, including (a) state regulation of conduct arguably protected or prohibited by the NLRA (often associated with *Garmon*) and (b) state regulation of economic weapons Congress meant to leave to the parties’ economic contest (often associated with *Machinists*).
- The fact that federal labor law permits certain conduct does not necessarily mean the conduct is affirmatively protected from any state restriction; preemption turns on whether Congress meant to displace state authority in that area and whether state law conflicts with federal labor policy.
- States retain authority to enact laws tied to local safety and public order concerns arising from labor disputes, so long as the law does not invade a field reserved to federal regulation or conflict with federal labor policy.
- Declaratory relief is available when the parties’ positions create a present, concrete controversy over the legality of intended conduct, rather than a purely hypothetical dispute.

## Conclusion

The Minnesota district court rejected Midwest Motor Express’s NLRA-preemption challenge and upheld Minnesota’s Striker Replacement Law, concluding that the state could bar employers from hiring or threatening to hire permanent strike replacements during a strike (while permitting temporary replacements) without violating the Supremacy Clause, and that Midwest’s announced intention to use permanent replacements made declaratory relief appropriate.


Midwest Motor Express, Inc. v. International Brotherhood of Teamsters, 139 L.R.R.M. 2563 (1992)