In the 1983 case of Westinghouse Electric Corp. v. Vaughn et al., the U.S Supreme Court was asked to consider whether a Pennsylvania state law that allowed employees to sue their employers for workplace injuries violated federal labor laws, which generally preclude such lawsuits in favor of workers' compensation claims. The plaintiffs were employees who had been injured on the job and sought damages from Westinghouse under state law, while Westinghouse argued that these claims were preempted by federal labor law. However, the court ruled in favor of Vaughn and his fellow plaintiffs, holding that their lawsuit could proceed because it did not conflict with any provision or objective of federal labor legislation.

The dissenting opinion in the case of Westinghouse Electric Corp. v. Vaughn et al., 1983, argued that the majority's decision to allow a private party to sue under Section 301 of the Labor Management Relations Act (LMRA) for breach of a collective bargaining agreement was inconsistent with previous court rulings and Congressional intent. The dissent contended that Congress intended Section 301 suits to be limited to disputes between employers and labor organizations, not individual employees. They also pointed out that allowing individuals to bring such lawsuits could undermine union authority and disrupt industrial relations by encouraging litigation over negotiation as a means of resolving disputes. Furthermore, they disagreed with the majority's interpretation of DelCostello v International Brotherhood Teamsters as providing precedent for this expansion when it only allowed hybrid §301/fair representation claims against both employer and union within six months after accrual.