Szot v. Florida Industrial Commission

How later courts describe this case

• borrowing state limitations period where cause of action based on breach of duty of fair representation
• applying contract statute but narrowly limiting holding to particular case, reserving question of applicability of tort limitations statute in subsequent cases
• affirming district court’s dismissal of complaint seeking damages for loss of services of employee killed in crash of defendant’s airplane, since corporation had no cause of action arising from death of its employee under common law or West Virginia statute
• that § 301 would create federal jurisdiction over claim under local constitution "open to grave doubt”
• no federal 301 jurisdiction over claim of civil conspiracy to violate labor contract
• whether activity is “integral and indispensable part” of principal activity is question of law
• no § 412 cause of action for conspiracy
• "mere conclusions of law [are] insufficient under Rule 8(a)”