this seems to be a morning preemption issues of vital importance to the international such a machinist district large seven fifty one because we represent twenty thousand employees of the phone company under the collective bargaining agreement specifically an issue in this case i will not really argue what i've argued in the amicus brief there has been no response by going through that grief in writing that i'm aware of this court set forth in the home both decision very clear guidelines on the test for preemption what i want to talk about is why this is so important to district large than fifty one and to talk about that it's important to think about what the role of the union address really exist unions exist are going contracts collectively on behalf of our members we sit down with employers and we bargain multi y collective bargaining agreements which set forth which rates and working conditions for our members are represented in points and that our role is to enforce those contracts you can members complain or if we see that  right all employees have all workers have to not be discriminated against based on their race their gender their age their disability or the other we're very well know of statutory rights and there are a labrat b say that the union has to investigate and pursue any claim of race discrimination sex discrimination disability discrimination moreover it's not fair t corporate complete policies our company policies have to be interpreted to defend against this will be discrimination so i understand this but the disability commission claim and our company policies are so intertwined with our collective bargaining agreement as to make the whole thing preempted and as we suggested in the brief it isn't that the number of portals the phone would have to get through fails to me is somehow preempted and the problem of course is that companies probably all kinds of policies unilaterally and have the right to do that and the bottom line is that boeing is attempting to create it would prove that we acted consistent with our policies you have to not only refer to you but necessarily interpret something in the collective bargaining agreement there's really no evidence in this record that the policies themselves are ambiguous much less that  those complaints each of those causes of action is a state law cause of action and i mention that because even if the court does ultimately determine that the humble decision is controlling here and means that the washington log substantial interpretation one is one of the work functions of the job title what does that mean  you're looking at the reasonable of the employer's  a little bit of an abstract distinction i think that is actually the way the cases come down if it's a matter of trying to negate the plaintiff to ask show reasonable accommodation as an affirmative part of the plaintiff's case and we're trying to negate that by showing that we did fail provide reasonable accommodation it doesn't matter how many cards they say whether the contract we only need to place such an employee in available work if the state law requires one to do something more than that for example requires boeing to make violating the contract price or seniority rights and i think what we come down to from humble is simply while it's conceivable it is far from guaranteed we have not actually seen anything in the records to make us think that boeing would have given  just there's nothing in this record which suggests model you get a court judge is going to have to read the contract refer to the contract but actually have to wrestle with a hard issue of contract interpretation we are so far from the in this record i think public policy suggesti policy of labor relations and collective bargaining suggests that we don't want what will in fact happen if distinguished in some way in this case is that every state law discrimination claim will will way a state court judge can decide this case without wrestling with the interpretation of difficult interpretation of sixteen point six letters norway's the court can resolve this case then we're going to say it's just a potential defense you can't use it