Hanley v. Lobster Box Restaurant, Inc.
This decision addresses a motion to dismiss filed by third-party defendant Hotel Employees and Restaurant Employees Union, Local 100, against the third-party complaint of Lobster Box Restaurant, Inc. Lobster Box sought a declaration that its collective bargaining agreement with Local 100 was voidable due to alleged fraud and misrepresentation, and requested indemnification. Presiding Judge Berman, citing Textron Lycoming, determined that the court lacked subject matter jurisdiction under LMRA § 301, as the statute applies to contract violations and not claims of contract invalidity. Furthermore, the court declined to exercise supplemental jurisdiction over Lobster Box's state common law claims, deferring to the exclusive competence of the National Labor Relations Board under the Garmon preemption doctrine. Consequently, the third-party complaint was dismissed.