Federal Labor Law Preemption of State Anti-Takeover Law: A Case of First Impression—Air Line Pilots Association, International v. UAL Corp., 874 F.2d 439 (7th Cir. 1989)

Authors

Patrick M. Madden

Abstract

Federal labor laws generally preempt state laws that conflict with or frustrate the federal labor scheme. In Air Line Pilots Association, International v. UAL Corp., the Seventh Circuit held that federal law did not preempt an anti-takeover statute that invalidated anti-takeover provisions in a collective bargaining agreement. This Note analyzes the court's holding and suggests that the court misapplied judicial precedent. Because state anti-takeover laws as applied to labor agreements conflict with and frustrate the federal labor scheme, this Note concludes that these state laws should be preempted.

First Page

457

Recommended Citation

Patrick M. Madden, Note, Federal Labor Law Preemption of State Anti-Takeover Law: A Case of First Impression—Air Line Pilots Association, International v. UAL Corp., 874 F.2d 439 (7th Cir. 1989), 65 Wash. L. Rev. 457 (1990).
Available at: https://digitalcommons.law.uw.edu/wlr/vol65/iss2/15