meant him to have available.” Machinists, 427 U.S. at 149-50, 96 S.Ct. at 2557-58. It should be noted that Machinists does not necessarily render a state law invalid merely because it might have some effect on labor-management relations. In Garmon, the Court recognized that states may enact statutes having only a peripheral impact on matters governed by federal labor law if they address concerns “deeply rooted in local feeling and responsibility.” Garmon, 359 U.S. at 254, 79 S.Ct. at 785. However, this exception is a narrow one and is limited to legislation directly aimed at topics of vital local concern such as health or welfare benefits and the prevention of violence or tortious acts. See, e.g., Belknap, Inc. v. Hale, 463 U.S. 491, 500, 103 S.Ct. 3172, 3177-78, 77 L.Ed.2d 798 (1983) (<HOLDING>); New York Telephone Co. v. New York State
holding that causes of action for employers misrepresentation and breach of contract to replacement workers are not preempted recognizing that the elements of a claim for breach of contract are 1 existence of a valid contract and 2 breach of the terms of that contract holding misrepresentation claim to be preempted holding breach of contract claim not preempted as a straightforward breach of contract action as it alleged violation of specific covenant holding that erisa preempted plaintiffs commonlaw causes of action including tortious breach of contract breach of fiduciary duties and fraud in the inducement that arose from a denial of benefits under the insurance contract