Craig Cortes v. Mass Electric Construction Co.

CourtDistrict Court, N.D. California
DecidedDecember 18, 2025
Docket3:25-cv-06714
StatusUnknown

This text of Craig Cortes v. Mass Electric Construction Co. (Craig Cortes v. Mass Electric Construction Co.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Craig Cortes v. Mass Electric Construction Co., (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 CRAIG CORTES, Case No. 25-cv-06714-JSC

8 Plaintiff, ORDER RE: MOTION TO REMAND v. 9 Re: Dkt. No. 12 10 MASS ELECTRIC CONSTRUCTION CO., Defendant. 11

12 13 Plaintiff brings this lawsuit under California’s Private Attorneys General Act alleging 14 various California Labor Code violations. (Dkt. No. 4-1.)1 Defendant removed this case to 15 federal court, asserting federal question jurisdiction on the grounds Plaintiff’s claims are 16 completely preempted by Section 301 of the Labor Management Rights Act since the claims are 17 subject to exemptions under California state law and require interpretation of collective bargaining 18 agreements. (Dkt. No. 4.) Now pending before the Court is Plaintiff’s motion to remand. (Dkt. 19 No. 12.) Having carefully reviewed the parties’ submissions, and having the benefit of oral 20 argument on December 4, 2025, the Court GRANTS Plaintiff’s motion to remand. Remand is 21 required because Defendant has not met its burden of demonstrating Plaintiff’s claims are 22 completely preempted by federal law under Burnside v. Kiewit Pacific Corp., 491 F.3d 1053 (9th 23 Cir. 2007). Causes of action II, III, and IV do not support removal jurisdiction under step one of 24 the Burnside test because the statutory exemptions upon which Defendant relies are affirmative 25 defenses that cannot create federal question subject matter jurisdiction. Nor is cause of action I 26 1 Record citations are to material in the Electronic Case File (“ECF”); pinpoint citations are to the 27 ECF-generated page numbers at the top of the documents. Because Docket No. 4-1 is a 1 preempted under step two because Defendant has not identified an active dispute over the 2 collective bargaining agreements’ terms such that litigating the claim requires an interpretation of 3 the agreements. Consequently, the Court does not have subject matter jurisdiction over causes of 4 action V and VI, which are derivative of Plaintiff’s first four claims. 5 BACKGROUND 6 Plaintiff sued Defendant in the Contra Costa County Superior Court on June 30, 2025. 7 (Dkt. No. 4 ¶ 4.) Plaintiff brings claims under California’s Private Attorneys General Act 8 (“PAGA”) for (1) failure to pay minimum wages, (2) failure to pay wages and overtime, (3) failure 9 to provide meal periods, (4) failure to provide rest breaks, (5) violation of Labor Code section 10 226(a) and 1174, and (6) violation of Labor Code sections 201 and 203. (Dkt. No. 4-1.) Plaintiff 11 served Defendant with the complaint on July 9, 2025. (Dkt. No. 4 ¶ 5.) 12 Defendant filed a Notice of Removal on August 8, 2025, alleging the Court has federal 13 question subject matter jurisdiction under the Labor Management Relations Act of 1974 14 (“LMRA”) and the National Labor Relations Act of 1935 (“NLRA”). (Id. ¶¶ 10-11.) Specifically, 15 Defendant contends Plaintiff’s causes of action are preempted by § 301 of the LMRA, which 16 provides “[s]uits for violation of contracts between an employer and a labor organization ... may 17 be brought in any district court of the United States.” 29 U.S.C. § 185(a). 18 DISCUSSION 19 A. Legal Standard 20 “The strong presumption against removal jurisdiction means that the defendant always has 21 the burden of establishing that removal is proper, and that the court resolves all ambiguity in favor 22 of remand to state court.” Hunter v. Philip Morris USA, 582 F.3d 1039, 1042 (9th Cir. 2009) 23 (cleaned up). Federal courts must “reject federal jurisdiction if there is any doubt as to the right of 24 removal in the first instance.” Grancare, LLC v. Thrower by & through Mills, 889 F.3d 543, 550 25 (9th Cir. 2018) (cleaned up). 26 Under the “well-pleaded complaint rule,” “federal jurisdiction exists only when a federal 27 question is present on the face of the plaintiff’s properly pleaded complaint.” Caterpillar, Inc. v. 1 “a case may not be removed to federal court on the basis of a federal defense, including the 2 defense of pre-emption, even if the defense is anticipated in the plaintiff’s complaint[.]” Id. at 3 392–93 (italics in original). “A corollary to the well-pleaded complaint rule is the ‘complete 4 preemption’ doctrine, which applies in cases in which ‘the preemptive force of a statute is so 5 extraordinary that it converts an ordinary state common-law complaint into one stating a federal 6 claim for purposes of the well-pleaded complaint rule.’” In re NOS Commc'ns, MDL No. 1357, 7 495 F.3d 1052, 1057 (9th Cir. 2007) (quoting Caterpillar, 482 U.S. at 393).

8 In spite of its title, the “complete preemption” doctrine is actually a doctrine of jurisdiction and is not to be confused with ordinary 9 preemption doctrine (although it is related to preemption law). Thus, the ‘complete preemption’ doctrine does not abrogate the standard 10 rule that a defense of preemption does not create federal question jurisdiction. 11 Balcorta v. Twentieth Century-Fox Film Corp., 208 F.3d 1102, 1107 n.7 (9th Cir. 2000). 12 “Although § 301 contains no express language of preemption, the Supreme Court has long 13 interpreted the LMRA as authorizing federal courts to create a uniform body of federal common 14 law to adjudicate disputes that arise out of labor contracts.” Curtis v. Irwin Indus., Inc., 913 F.3d 15 1146, 1151 (9th Cir. 2019) (citing Allis-Chalmers Corp. v. Lueck, 471 U.S. 202, 210 (1985)). As a 16 result, “a civil complaint raising claims preempted by § 301 raises a federal question that can be 17 removed to a federal court.” Id. at 1152. But “§ 301 cannot be read broadly to pre-empt 18 nonnegotiable rights conferred on individual employees as a matter of state law.” Livadas v. 19 Bradshaw, 512 U.S. 107, 123 (1994). 20 In Burnside v. Kiewit Pacific Corp., the Ninth Circuit adopted a two-part test for analyzing 21 whether § 301 preempts a state law claim. 491 F.3d 1053, 1059 (9th Cir. 2007). Under the 22 Burnside test, courts first “ask whether the asserted cause of action involves a right [that] exists 23 solely as a result of the [collective bargaining agreement (“CBA”)].” Curtis, 913 F.3d at 1152 24 (cleaned up). If the answer to the first question is yes, then “the claim is preempted and [the] 25 analysis ends there.” Id. at 1152–53 (quoting Burnside, 491 F.3d at 1059). If the answer to the 26 first question is no, then courts “proceed to the second step and ask whether a plaintiff's state law 27 right is substantially dependent on analysis of” the CBA. Id. (cleaned up). To answer this 1 question, courts consider “whether the claim cannot be resolved by simply look[ing] to versus 2 interpreting the CBA.” Id. (cleaned up); see also Livadas, 512 U.S. at 124 (“[W]hen the meaning 3 of contract terms is not the subject to dispute, the bare fact that a collective bargaining agreement 4 will be consulted in the course of state-law litigation plainly does not require the claim to be 5 extinguished[.]”) 6 Here, as is explained below, Defendant has not met its burden of establishing federal 7 question subject matter jurisdiction based on § 301 preemption. Plaintiff’s complaint does not rely 8 solely on a collective bargaining agreement as the source for any cause of action.

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Bluebook (online)
Craig Cortes v. Mass Electric Construction Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/craig-cortes-v-mass-electric-construction-co-cand-2025.