L.Ed.2d 565 (1993). Even so, it is not a typical field preemption doctrine. See Trollinger v. Tyson Foods, Inc., 370 F.3d 602, 608-09 (6th Cir.2004). The primary rationale for Garmon preemption is jurisdictional. By creating the NLRB, Congress sought to give a specialized body power to create a uniform scheme of regulation. See Garner v. Teamsters, Chauffeurs & Helpers Local Union No. 776 (A.F.L.), 346 U.S. 485, 491, 74 S.Ct. 161, 98 L.Ed. 228 (1953); Northwestern Ohio Adm’r, Inc. v. Walcher & Fox, Inc., 270 F.3d 1018, 1027 (6th Cir.2001). Garmon preemption is thus designed to preserve the NLRB’s primary jurisdiction by generally precluding other governmental entities from regulating activities described in Sections 7 and 8 of the NLRA. See Gould, Inc., 475 U.S. at 286, 106 S.Ct. 1057 (<HOLDING>); Garmon, 359 U.S. at 244-45, 79 S.Ct. 773.
holding that if adequate administrative remedies are available it is improper to seek relief in court before those remedies are exhausted recognizing that garmon precludes states from enacting even supplemental remedies holding that statute of limitations is tolled by pursuit of internal union remedies even where those remedies are ultimately determined to be futile recognizing that unfairness precludes an appellate court from affirming on a factdependent ground not determined below holding that the remedies are exclusive