(1) Whether a state labor claim that requires the
plaintiff to show that an employer acted with
"willfulness," "unreasonableness," or other mental
state, which can be resolved only through
interpretation of the terms of the pertinent collective
bargaining agreement, is preempted by section 301 of
the Labor Management Relations Act ("LMRA').

(2) Whether a state-law rule, which imposes a
higher burden of proof for establishing waivers of
wage-and-hour rights contained in_ collective
bargaining agreements than it does for individual
waivers of those same rights outside the collective
bargaining context, is preempted by the National
Labor Relations Act ("NLRA").

Whether a state labor claim that requires the plaintiff to show that an employer acted with 'willfulness,' 'unreasonableness,' or other mental state, which can be resolved only through interpretation of the terms of the pertinent collective bargaining agreement, is preempted by section 301 of the Labor Management Relations Act