Hanna Gebregzi v. Kaiser Foundation Hospitals, et al.

Background

Hanna Gebregzi was employed by Kaiser as a nurse until Kaiser terminated her employment on August 17, 2025. She was covered by a collective bargaining agreement among Kaiser, The Permanente Group, and the California Nurses Association.

She filed this case in Alameda County Superior Court against Kaiser and seven individuals. Her claims were: failure to engage in the interactive process under California’s Fair Employment and Housing Act; disability discrimination and failure to accommodate under that Act; whistleblower retaliation under California Labor Code section 1102.5; wrongful termination in violation of public policy; intentional infliction of emotional distress; negligent infliction of emotional distress; and retaliation under the Fair Employment and Housing Act.

Kaiser removed the case to federal court under Section 301 of the Labor Management Relations Act. Kaiser argued that several claims were connected to the collective bargaining agreement. Because the complaint asserted only state-law claims and no breach-of-contract or federal claims, the court ordered Kaiser to explain which claims depended on rights created by the agreement and which agreement provisions required interpretation. Kaiser filed a response; Gebregzi did not respond.

Jurisdiction and preemption analysis

The party that removes a case to federal court bears the burden of showing federal jurisdiction. The court explained that federal-question jurisdiction generally depends on the claims stated in the plaintiff’s complaint. Section 301 of the Labor Management Relations Act can completely preempt certain state-law claims, meaning that a claim based on state law may be treated as a federal claim when it is founded on rights created by a collective bargaining agreement or substantially depends on interpreting that agreement.

The court applied a two-step test. First, it considered whether each asserted right came from state law rather than the agreement. Second, it considered whether resolving the claim required interpretation of the agreement. The court emphasized that merely referring to an agreement, considering its terms, applying them, or using the agreement as a defense is not enough. Preemption requires more than a hypothetical connection and applies only when there is an active dispute about the meaning of agreement terms.

Kaiser identified agreement provisions concerning overtime opportunities, seniority-based assignments, administrative leave, discipline compensation, investigations, orientation processes, and progressive discipline. But Kaiser did not contend that those provisions were ambiguous or that the parties actively disputed their meaning. The court therefore concluded that Kaiser had not carried its burden to establish federal jurisdiction based on Section 301 preemption.

Ruling

The court denied Kaiser’s motion to dismiss without prejudice. It ordered that the case be remanded to Alameda County Superior Court and directed the Clerk to close the federal case. The ruling addressed federal jurisdiction and removal; it did not decide the merits of Gebregzi’s employment and retaliation claims.