Darin Ruf v. The Cincinnati Reds

Summary

The court grants Darin Ruf’s motion to remand his Ohio negligence action against the Cincinnati Reds to state court. It holds that Ruf’s premises-liability, vicarious-liability, and negligent hiring and supervision claims are not substantially dependent on interpreting the Major League Baseball collective-bargaining agreements and therefore are not preempted under section 301 of the Labor Management Relations Act. The excerpt addresses the asserted relevance of the CBAs’ grievance provisions, baseball rules and regulations, Safety and Health Advisory Committee provisions, and compensation provisions.

Holdings

1. Ruf's negligence claims were independent of the collective-bargaining agreements and were not completely preempted under § 301 of the LMRA; therefore, the federal court lacked subject-matter jurisdiction and remand was required.
2. The identified provisions did not require interpretation to resolve Ruf's negligence claims. The baseball rules and regulations did not address the manner in which the tarp was stored; the Safety and Health Advisory Committee was advisory and did not establish a contractual standard of care; the grievance and safety-complaint provisions had no alleged application to Ruf's claim; and compensation provisions did not govern claims against the Reds for conditions at the stadium.
3. Ruf was entitled to reasonable attorneys' fees and costs incurred as a result of the removal because the Reds lacked an objectively reasonable basis for removal.

Questions Presented

1. Whether Ruf's Ohio negligence claims were completely preempted under § 301 of the Labor Management Relations Act such that removal to federal court was proper.
2. Whether adjudicating Ruf's negligence claims required interpretation of the parties' collective-bargaining agreements, incorporated Major League Baseball rules and regulations, safety-committee provisions, grievance provisions, or compensation provisions.
3. Whether Ruf was entitled to attorneys' fees and costs under 28 U.S.C. § 1447(c) because the Reds lacked an objectively reasonable basis for removal.

Disposition

remanded