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When ERISA Is Itself Preempted
Kantor & Kantor 
Apr. 8, 2026 "Plaintiffs contended that the Garmon doctrine [1] only applies to state law claims, and [2] only applies to federal claims 'within the jurisdiction of the NLRB,' i.e., not ERISA claims. The Sixth Circuit rejected both arguments. The court emphasized that the doctrine applies to all federal claims arising from activities arguably subject to the NLRA, including ERISA claims.... According to the Sixth Circuit, 'Plaintiffs' ERISA claims can succeed 'only if' Defendants' 'conduct violates the NLRA,' rendering the NLRA issues 'anything but collateral.' " [Rieth-Riley Construction Co., Inc. v. Trustees of the Operating Engineers' Local 324 Fringe Benefit Funds, No. 25-1823 (6th Cir. Apr. 3, 2026)] MORE >> |
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