## Facts

- Kevin Williams and Pat Williams, NFL players for the Minnesota Vikings, were subject to the NFL’s collectively bargained Policy on Anabolic Steroids and Related Substances (Policy) incorporated into the 2006 CBA.
- The Policy prohibited certain “masking agents,” including diuretics, and imposed strict responsibility on players for any prohibited substance found in their bodies, regardless of intent or knowledge.
- The players ingested an over-the-counter weight-loss supplement, StarCaps, which contained an undeclared ingredient, bumetanide, a prescription diuretic and banned masking agent under the Policy.
- The NFL notified the players of positive tests for bumetanide and imposed four-game suspensions without pay.
- The suspensions were upheld through the Policy’s internal appeal procedure by an arbitrator designated under the CBA/Policy framework.
- The players sued in Minnesota state court asserting Minnesota statutory claims (including under the Drug and Alcohol Testing in the Workplace Act (DATWA)) and Minnesota common-law claims (including negligence and misrepresentation) based on alleged failures to disclose information about StarCaps and testing/discipline procedures.
- The NFL removed the case to federal court asserting LMRA § 301 jurisdiction; the district court enjoined enforcement temporarily, held DATWA claims not preempted but common-law claims preempted, and confirmed the arbitration awards.
- Multiple parties appealed; the Eighth Circuit reviewed § 301 preemption and the confirmation of the arbitration awards.

## Issues

1. Whether LMRA § 301 preempted the players’ Minnesota statutory claims, including DATWA, because resolving them would require interpreting the CBA and Policy.
2. Whether LMRA § 301 preempted the players’ Minnesota common-law claims as substantially dependent on CBA/Policy interpretation.
3. Whether the arbitration awards upholding the suspensions should be vacated for evident partiality, manifest disregard of law, or violation of public policy.

## Decision

- The Eighth Circuit affirmed the district court in all respects.
- The court held the Minnesota statutory claims, including DATWA claims, were not preempted by LMRA § 301 because they could be resolved without interpreting the CBA/Policy.
- The court held the Minnesota common-law claims were preempted because they were inextricably intertwined with rights and duties defined by the CBA and Policy.
- The court affirmed confirmation of the arbitration awards, rejecting challenges based on evident partiality, manifest disregard, and public policy.

## Legal Principles

- LMRA § 301 preempts state-law claims that are substantially dependent on analysis or interpretation of a collective bargaining agreement, but not claims that can be resolved through factual inquiries without interpreting the agreement.
- State statutory regulation of workplace drug testing may proceed alongside a CBA-based testing program when adjudication turns on what procedures were followed rather than the meaning of CBA provisions.
- Common-law tort theories are preempted when determining duty, breach, or causation requires construing the CBA/Policy allocation of responsibilities, warnings, and disciplinary procedures.
- Courts apply highly limited review to labor-arbitration decisions; an award is sustained if it draws its essence from the collectively bargained agreement.
- A claim of “evident partiality” is not established merely because an arbitrator is a league official when the union knowingly agreed in the CBA to that arbitral structure.
- Under a bargained-for strict-liability anti-doping regime, discipline may be upheld based on detection of a prohibited substance regardless of the player’s knowledge of mislabeled or contaminated supplements.

## Conclusion

The Eighth Circuit allowed Minnesota statutory drug-testing claims to proceed because they did not require interpreting the CBA, barred related common-law tort claims as § 301-preempted, and upheld the players’ suspensions by confirming arbitration awards issued under the CBA’s agreed internal arbitration process.


Williams v. Nat’l Football League, 582 F.3d 863 (8th Cir. 2009)