This note will explore the history of Section 301 of the Labor Management Relations Act 6 (LMRA) and the preemption doctrine, the development of the wrongful discharge action, the case history involving union employees filing state actions for wrongful discharge, and the effect the Lingle decision will have on business, the judicial system and, most importantly, the body politic of the individual states. Emphasis will be placed on the important role the state legislature will play in determining the exact ramifications of the Supreme Court's decision. Finally, the note will outline and discuss four main options state legislatures have when considering whether to expand upon the Supreme Court's decision or to circumvent the potential for remedial "double dipping."



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