Argento v. Airborne Freight Corp.
Salvatore Argento sued Airborne Freight Corporation and Local 851 for negligence, alleging that his spouse became addicted to drugs during her employment at Airborne. Local 851 moved to dismiss the complaint for failure to state a claim, arguing it owed no duty to Argento to ensure a safe workplace for his spouse. The court found that Argento's claim, based on a common law negligence theory, was either preempted by federal labor law due to its reliance on a collective bargaining agreement or failed under common law because unions generally do not owe a duty to provide a safe workplace, and even if they did, it wouldn't extend to a non-employee spouse. Consequently, Local 851's motion to dismiss was granted, and the complaint against it was dismissed with prejudice.