Seyfarth Synopsis: The California Supreme
Court held that the Labor Management Relations Act does not preempt
claims under the Labor Code where a defense requires little more
than referring to a collective bargaining agreement, as opposed to
actually interpreting the agreement. Melendez v. San Francisco
Baseball Associates LLC.
The Facts
The plaintiffs, security guards at San Francisco's Oracle
Park (the former AT&T Park), sued their employer, San Francisco
Baseball Associates LLC ("the Giants"), alleging a
violation of California Labor Code section 201 for failure to pay
all wages due at the time of termination.
The security guards claimed that they were employees who were
discharged intermittently—at the end of each Giants
homestand, at the end of the baseball season, and at the end of
other events at the park. Consequently, the security guards claimed
that they were entitled to receive their unpaid wages immediately
after each discharge, as required by
