Cylo Van Roeun v. Simpson Strong-Tie Company, Inc.

Background

Cylo Van Roeun filed a wage-and-hour lawsuit in state court asserting only state-law claims. Simpson Strong-Tie Company, Inc. removed the case to federal court. Simpson argued that the Labor Management Relations Act of 1947 preempts some of Van Roeun’s claims, creating federal-question jurisdiction through the complete-preemption doctrine.

Simpson specifically relied on California Labor Code sections 204(c), 245.5(a)(1), and 514. Those provisions exempt certain employees covered by qualifying collective bargaining agreements. Simpson argued that because Van Roeun could not assert the claims under state law, the claims were really claims under the collective bargaining agreement presented as state-law claims.

Jurisdictional issue

The court stated that it had previously concluded, based on Curtis v. Irwin Industries, Inc., that claims covered by section 514 and similar exemptions are preempted by the Labor Management Relations Act and therefore can create federal-question jurisdiction. The court also noted that a growing minority of courts had persuasively concluded that Curtis did not and could not establish complete preemption under section 514.

Those courts reasoned that section 514 and similar provisions are affirmative defenses under California law. Under the well-pleaded complaint rule, a federal issue raised only as a defense generally does not create federal jurisdiction. The court stated that similar reasoning appeared to apply to sections 204(c) and 245.5(a)(1): section 204(c) uses language similar to section 514, while section 245.5(a)(1) describes its exclusion of certain employees covered by collective bargaining agreements as an exemption.

Order

The court ordered Simpson Strong-Tie to show cause in a written statement of no more than five pages by October 5, 2026, why the case should not be remanded to state court for lack of subject-matter jurisdiction. Van Roeun may file a response of no more than five pages by October 13, 2026. The order did not finally resolve the jurisdiction question or remand the case.