Utility Workers Union v. Southern California Edison Co.

How later courts describe this case

• “Drug testing does not implicate the sort of ‘nonnegotiable state-law rights’ that preclude preemption under section 301.”
• district court erred in issuing injunction against implementation of drug testing program where employer did not expressly or impliedly promise to maintain status quo pending arbitration
• employees’ claim that employer’s unilateral initiation of drug-testing program under general collective-bargaining rights was violation of state constitutional rights to privacy and freedom from unreasonable search and seizures held preempted