the picketing of a freight rail terminal facility under state tort and labor laws. 394 U.S. at 372-77, 89 S.Ct. 1109. The Court concluded that it did not because “the exercise of plenary state authority to curtail or entirely prohibit self-help would frustrate effective implementation of the [RLA’s] processes.” Id. at 380, 8 not falling squarely within either category, see, e.g., Kaufman v. Allied Pilots Ass’n, 274 F.3d 197, 202-03 (5th Cir.2001) (applying Garmon to hold third-party tortious interference claim preempted by RLA); Air Transp. Ass’n of Am. v. City & County of San Francisco, 266 F.3d 1064, 1076 (9th Cir.2001) (noting that “[sjtate laws that frustrate the purpose of the RLA are preempted”); Peterson v. Air Line Pilots Ass’n, Int'l, 759 F.2d 1161, 1170-71 (4th Cir.1985) (<HOLDING>); cf. Delta Air Lines v. Kramarsky, 650 F.2d
holding rla duty of fair representation claim preempts identical state law claims of fraud and deceit holding that the plaintiffs state law claims are preempted by federal law holding that rla preempts state law claim for wrongful discharge even where rla arbitral mechanism not implicated because state claims seek to vindicate rights largely secured by federal law holding that the flsa preempts certain state law claims holding that general maritime law preempts state law