In Johnson v. Rancho Santiago Comm. Coll. Dist., No. 08-56963, an action challenging a public project labor agreement as preempted by the National Labor Relations Act (NLRA) and the Employee Retirement Income Security Act (ERISA) and as violative of their rights to substantive and procedural due process and to equal protection, the court affirmed summary judgment for defendants where 1) entering into the agreement constituted market participation not subject to preemption by the NLRA or ERISA; 2) the agreement did not violate the plaintiffs' liberty interest in pursuing their careers as electricians; and 3) the agreement was rationally related to the district's legitimate interest in preventing labor disruptions.
As the court wrote: "In 2003, Rancho Santiago Community College District ("the District") entered into a project labor agreement with the Los Angeles and Orange Counties Building and Construction Trades Council ("the Council") and its affiliated construction unions that governed labor relations for many District construction projects over a three-to-five-year period. The agreement required, among other things, that contractors use union "hiring halls" to obtain workers, that all workers on covered projects become union members within seven days of their employment, and that all contractors and subcontractors working on covered projects agree to the project labor agreement and to the master labor agreement negotiated by the union for each craft. Seven individual non-union apprentices and two non-union apprenticeship committees filed suit challenging the agreement as preempted by the National Labor Relations Act ("NLRA") and the Employee Retirement Income Security Act ("ERISA") and as violative of their rights to substantive and procedural due process and to equal protection. The district court granted the defendants summary judgment on all claims."