WILDER, J.

Plaintiff, Mark Packowski, appeals by right the circuit court's order granting summary disposition for defendant, United Food and Commercial Workers Local 951, under MCR 2.116(C)(4), and an order denying plaintiff's motion for reconsideration. Because we agree with the circuit court that federal preemption applies to plaintiff's remaining claim, we affirm.

I

Defendant employed plaintiff as a business agent and, later, as an organizer. In his complaint, plaintiff alleged that he was demoted from business agent to organizer in 1999 after he assisted in a federal Department of Labor investigation of defendant's election activities. Plaintiff further alleged that he was treated differently and excluded from staff events, such as training, because he refused to contribute to defendant's legal defense fund. Plaintiff alleged that, for these reasons, defendant subsequently terminated him against public policy. In an amended complaint, plaintiff also alleged that his termination violated defendant's just-cause policy, which prohibited defendant from discharging employees except for just cause. The sole issue before us on appeal is plaintiff's claim that he was terminated without just cause.

Plaintiff's complaint alleged that he had worked for defendant since 1995. According to the complaint, plaintiff took a medical leave from work from September 10, 2001, to September 14, 2001. Plaintiff alleged that he had returned to work for a half-day on September 14, but then a flareup of his health condition forced him to leave work.

Defendant asserted below that it discharged plaintiff on September 27, 2001, for being absent from work without authorization. Defendant also asserted that it terminated plaintiff for falsifying records, including his daily itinerary and mileage records for September 14, 2001. Defendant admitted that it had an employment policy that employees, including plaintiff, could only be terminated for just cause, but defendant denied that its termination of plaintiff violated that policy.

Defendant also had employment policies and standards that governed automobile use and business mileage reporting. The policies prohibited reimbursement for personal miles and required a monthly report specifying business and personal miles. The policies required accurate recordkeeping to ensure that defendant complied with the law. Departmental staff who had organizing duties, such as plaintiff, were also required to contact defendant by 9:00 a.m. every day to report their itineraries to a supervisor and to promptly contact a supervisor if any changes in itinerary occurred.

Defendant argued below that on or about September 9, 2001, plaintiff informed defendant by a voicemail message of a flareup in his health condition, but he did not communicate with defendant again regarding his condition or his resulting inability to work until September 14, 2001, when he faxed a note from his doctor indicating that he would be absent from September 10 to September 14. Defendant asserted that plaintiff reported that he was going to work the second shift at the Wal-Mart store in St. John's, Michigan, on September 14. Defendant later determined that plaintiff had not worked the full shift, because he left to referee a football game, and that plaintiff had failed to report a change in his itinerary. Defendant also asserted that plaintiff claimed that he had intended to stop at the Wal-Mart stores in Alma and Mt. Pleasant, Michigan, after the game, but had not informed defendant of this change in his itinerary, and, regardless, defendant contended that plaintiff went home after the game rather than to work as he had stated he would. Defendant further maintained that plaintiff falsified his mileage report for September 14, 2001, by overstating his business miles.

II

After plaintiff filed this action, defendant filed several motions for summary disposition. This appeal involves defendant's summary disposition motion regarding plaintiff's cause of action for wrongful termination in violation of defendant's just-cause policy. Defendant contended below that this claim was preempted by the Labor-Management Reporting and Disclosure Act (LMRDA), 29 U.S.C. 401 et seq. Defendant argued that, under Finnegan v. Leu, 456 U.S. 431, 102 S.Ct. 1867, 72 L.Ed.2d 239 (1982), the primary purpose of the LMRDA is to ensure union democracy. Thus, a union president, elected by the rank-and-file members, may terminate policymaking and policy-implementing employees without violating the LMRDA because the LMRDA does not restrict an elected union official's freedom to choose staff whose views reflect his or her own (which would be the views on the basis of which he or she was elected). Further, defendant argued that courts from other jurisdictions, relying on Finnegan, have held that the LMRDA preempts state-law wrongful-discharge claims by policymaking and policy-implementing employees, because such claims would interfere with the elected union leader's ability to implement the policy upon which the union members elected the leader.

Defendant also argued that plaintiff claimed that he was terminated because he cooperated with the Department of Labor's investigation of defendant's election activities and that this claim directly implicated the LMRDA's regulatory scheme because 29 U.S.C. 521(a)1 authorizes such an investigation and 29 U.S.C. 4122 provides for a civil action in federal court if there is retaliation based on giving truthful testimony to the Department of Labor. Thus, defendant argued, plaintiff's exclusive remedy was to file a retaliation claim under the LMRDA in federal court, and his state-law claim interfered with and was preempted by federal law. In response, plaintiff argued that his claim was not preempted by the LMRDA, that the LMRDA did not prohibit defendant from adopting a policy barring termination without just cause, and that he was not a management-level employee to which the LMRDA and caselaw interpreting the LMRDA would apply.

The circuit court granted defendant's motion. The circuit court concluded that plaintiff was a policy-implementing employee of defendant and that, as such, his state-law wrongful-termination claim, to the extent that it relied on defendant's just-cause policy, was preempted by the LMRDA because it would interfere with the union president's authority to choose his own staff and would thereby jeopardize union democracy. The circuit court denied plaintiff's subsequent request for reconsideration, determining that plaintiff had merely reiterated the same arguments addressed in the summary disposition motion and clarifying that summary disposition of plaintiff's claim had been granted under the substantive-preemption doctrine, not the jurisdictional-preemption doctrine.

III

Plaintiff argues on appeal that the circuit court erred by granting defendant's motion for summary disposition and by holding that his claim of wrongful discharge in violation of defendant's just-cause policy was preempted by the LMRDA. We disagree.

A

We review de novo a circuit court's summary disposition decision. Willett v. Waterford Charter Twp., 271 Mich.App. 38, 45, 718 N.W.2d 386 (2006). Issues of law, such as federal preemption of state law, are reviewed de novo. Detroit v. Ambassador Bridge Co., 481 Mich. 29, 35, 748 N.W.2d 221 (2008). Whether a court has subject-matter jurisdiction is also an issue of law, reviewed de novo. Fisher v. Belcher, 269 Mich.App. 247, 252-253, 713 N.W.2d 6 (2005). We review the circuit court's denial of plaintiff's motion for reconsideration for an abuse of discretion. Churchman v. Rickerson, 240 Mich.App. 223, 233, 611 N.W.2d 333 (2000).

Defendant moved for summary disposition under MCR 2.116(C)(4), (8), and (10). The circuit court decided the motion under subrule (C)(4). Summary disposition is appropriate when the trial court "lacks jurisdiction of the subject matter." MCR 2.116(C)(4). For jurisdictional questions under MCR 2.116(C)(4), this Court "`determine[s] whether the affidavits, together with the pleadings, depositions, admissions, and documentary evidence, demonstrate. . . [a lack of] subject matter jurisdiction.'" L & L Wine & Liquor Corp. v. Liquor Control Comm., 274 Mich.App. 354, 356, 733 N.W.2d 107 (2007) (citations omitted).

B

The Supremacy Clause of the United States Constitution gives Congress the authority to preempt state laws. Ambassador Bridge, 481 Mich. at 35-36, 748 N.W.2d 221. The Supremacy Clause of the United States Constitution provides:

Under the Supremacy Clause, then, this Court is bound by federal statutes, despite any state law to the contrary. In other words, this Court is bound to find preemption when it exists because federal law is the supreme law of the land. See Ambassador Bridge, 481 Mich. at 36, 748 N.W.2d 221.

Whether a federal statute preempts a state-law claim is a question of federal law. Allis-Chalmers Corp. v. Lueck, 471 U.S. 202, 214, 105 S.Ct. 1904, 85 L.Ed.2d 206 (1985). When such questions of federal law are involved, we are bound to follow the prevailing opinions of the United States Supreme Court. Betty v. Brooks & Perkins, 446 Mich. 270, 276, 521 N.W.2d 518 (1994). If a state-law proceeding is preempted by federal law, the state court lacks subject-matter jurisdiction to hear the state-law cause of action. Ryan v. Brunswick Corp., 454 Mich. 20, 27, 557 N.W.2d 541 (1997), overruled in part on other grounds by Sprietsma v. Mercury Marine, 537 U.S. 51, 123 S.Ct. 518, 154 L.Ed.2d 466 (2002).

"Preemption occurs when a state law stands as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress." Ambassador Bridge, 481 Mich. at 36, 748 N.W.2d 221 (quotation marks and citation omitted). Preemption can also occur when a state or local regulation prevents a private entity from performing a function that Congress has tasked it with performing. Id.

There are three types of federal preemption: express preemption, conflict preemption, and field preemption. X v. Peterson, 240 Mich.App. 287, 289, 611 N.W.2d 566 (2000). Express preemption occurs when a federal statute clearly states an intent to preempt state law or that intent is implied in a federal law's purpose and structure. Ryan, 454 Mich. at 28, 557 N.W.2d 541. Under conflict preemption, a federal law preempts state law to the extent that the state law directly conflicts with federal law or with the purposes and objectives of Congress. Id., citing Cipollone v. Liggett Group, Inc., 505 U.S. 504, 516, 112 S.Ct. 2608, 120 L.Ed.2d 407 (1992). Field preemption acts to preempt state law when federal law so thoroughly occupies a legislative field that it is reasonable to infer that Congress did not intend for states to supplement it. Ryan, 454 Mich. at 28, 557 N.W.2d 541.

A few of our sister states have considered analogous situations, and analogous state-law claims, and have found that the LMRDA conflict-preempted those claims. While we are not bound by those decisions, we may follow them if we find them persuasive. Mettler Walloon, LLC v. Melrose Twp., 281 Mich.App. 184, 221 n. 6, 761 N.W.2d 293 (2008).

One closely analogous case is Screen Extras Guild, Inc. v. Superior Court, 51 Cal.3d 1017, 1024-1032, 275 Cal.Rptr. 395, 800 P.2d 873 (1990), in which it was held that California common law, which implied a covenant of good faith and fair dealing in some employment relationships, conflicted with the LMRDA and was preempted. The plaintiff in Screen Extras was employed by the union as a business agent and was discharged for alleged dishonesty and insubordination. The plaintiff sued for wrongful discharge, among other claims, and alleged that the union breached a state-law covenant of good faith and fair dealing. Id. at 1027, 275 Cal.Rptr. 395, 800 P.2d 873. Analyzing whether the plaintiff's state-law cause of action conflicted with the LMRDA's policy, the court relied on Finnegan in holding that in order to ensure union democracy, "Congress must have intended that elected union officials would retain unrestricted freedom to select business agents, or, conversely, to discharge business agents with whom they felt unable to work or who were not in accord with their policies." Id. at 1025, 275 Cal.Rptr. 395, 800 P.2d 873 (emphasis added).

The plaintiff in Screen Extras argued that her claims for wrongful discharge in breach of contract, negligent and intentional infliction of emotional distress, and defamation were not preempted because she was terminated as a result of her alleged incompetence and dishonesty, not because of a policy disagreement with the union's elected officials. Id. at 1027, 275 Cal.Rptr. 395, 800 P.2d 873. The court found this distinction between a termination for policy reasons and a "garden-variety" termination not implicating policy unpersuasive because it was unworkable in the real world and involved highly subjective determinations. Id. at 1027-1028, 275 Cal.Rptr. 395, 800 P.2d 873. "If a business agent, for example, were discharged for failing to efficiently adopt a new set of procedures for prioritizing routine tasks which had been endorsed by elected officials, should that be characterized as a termination to facilitate policy, or as a `garden-variety' termination for inefficiency?" Id. at 1028, 275 Cal.Rptr. 395, 800 P.2d 873. The court in Screen Extras noted that it would be impossible to develop an objective test to distinguish the two, and "every wrongful discharge claim brought against a union by a business agent will be cast in `garden-variety' terms if that is all it takes to survive preemption." Id. Relying on Finnegan, the court held that the plaintiff's claim was preempted because it conflicted with the LMRDA:

See also Tyra v. Kearney, 153 Cal.App.3d 921, 925-927, 200 Cal.Rptr. 716 (1984) (relying on Finnegan, 456 U.S. at 441, 102 S.Ct. 1867, to hold that the plaintiff's claim for wrongful discharge, following termination from her position as a business agent for a union after she had run against the winning candidate, was preempted by the LMRDA's purpose of ensuring democratically governed unions and union officials' concomitant authority to select business agents).

Also analogous is Vitullo v. Int'l Brotherhood of Electrical Workers, Local 206, 317 Mont. 142, 75 P.3d 1250 (2003), in which the plaintiff was a former assistant business manager for a union local. The business manager fired the plaintiff after the plaintiff had accepted a nomination to run against the business manager in the next union election. Id. at 144, 75 P.3d 1250. The plaintiff brought a claim under Montana's Wrongful Discharge From Employment Act, which created a just-cause-for-termination requirement and a probationary period. See Mont. Code 39-2-901 et seq. The court held that the statutory claim conflicted with the LMRDA and Finnegan and was therefore conflict-preempted. Vitullo, 317 Mont. at 145-152, 75 P.3d 1250. See also Smith v. Int'l Brotherhood of Electrical Workers, Local Union 11, 109 Cal.App.4th 1637, 1648, 1 Cal.Rptr.3d 374 (2003) (holding that the plaintiff, a union organizer employee who was discharged and brought a breach of contract claim against the union, was a policymaking employee and that his breach-of-contract claim was preempted by the LMRDA).

In another case finding preemption, Dzwonar v. McDevitt, 348 N.J.Super. 164, 167, 791 A.2d 1020 (2002), the plaintiff was discharged from her position as a union arbitration officer for inappropriate behavior at an arbitration proceeding and for involvement in disputes with other union members. The plaintiff brought an action under New Jersey's Conscientious Employee Protection Act, arguing that she was fired in retaliation for objecting to a union official's acts that allegedly violated the LMRDA. Id. at 167-169, 791 A.2d 1020. Although the LMRDA contains no express provision limiting a state's right to protect union employees from retaliation in the plaintiff's circumstances, the court held that "such a limitation may be inferred from" the LMRDA's scope. Id. at 170, 791 A.2d 1020. Although the court adopted a preemption exception for claims based on an employee's unwillingness to aid in the violation of a criminal statute, citing Bloom v. Gen. Truck Drivers, Office, Food & Warehouse Union, Local 952, 783 F.2d 1356, 1360-1362 (C.A.9, 1986) (discussed further later in this opinion), the court held that the plaintiff's claim was preempted because it was not based on an allegation that the union official's acts were criminal. Dzwonar, 348 N.J.Super. at 173-174, 791 A.2d 1020. "Rather, this case involves, at most, the federal regulatory scheme and the union's own internal operating policies." Id. at 173, 791 A.2d 1020.

We conclude that the reasoning in Screen Extras, Tyra, Vitullo, Smith, and Dzwonar is persuasive. We adopt that reasoning and apply it to this case. Conflict preemption applies to preclude plaintiff's state-law action. The democratic purposes of the LMRDA would be contravened by allowing a demoted or discharged business agent or organizer to sue for wrongful discharge.

We decline to follow Young v. Int'l Brotherhood of Locomotive Engineers, 114 Ohio App.3d 499, 683 N.E.2d 420 (1996), a case in which the court concluded that preemption was not applicable. The plaintiff in Young was fired from her position as a union employee for allegedly being insubordinate and uncooperative and making derogatory remarks about the union president. Id. at 503, 683 N.E.2d 420. Denying these allegations, the plaintiff brought a breach-of-contract action based on her alleged 10-year contract with the union. Id. at 502-503, 683 N.E.2d 420. The trial court granted summary judgment, and the Ohio Court of Appeals reversed and remanded for trial, which resulted in a judgment for the plaintiff and an appeal by the union. Id. at 502, 683 N.E.2d 420. In the second appeal, the court held that whether the plaintiff's claim was preempted by the LMRDA depended on whether the plaintiff was a policymaking employee, which was an issue of fact for the jury to resolve. Id. at 504-506, 683 N.E.2d 420.

Unlike the parties in Young, plaintiff and defendant do not dispute the circuit court's finding that plaintiff was a policy-implementing employee. Therefore, Young is distinguishable from the instant case. We also find Young unpersuasive in that it concludes that the question of preemption is a jury question, despite the fact that whether state law conflicts with federal law is more properly characterized as a question of law. Ambassador Bridge, 481 Mich, at 35, 748 N.W.2d 221.

Other cases finding no conflict preemption are also more easily distinguished from the instant case than those cases finding preemption. In Bloom, 783 F.2d at 1359-1360, the plaintiff was a union business manager who sued the union for, among other claims, wrongful discharge after he was terminated, allegedly because he refused to falsify the union's minutes to cover up an unapproved expenditure. The plaintiff argued that his claim was not preempted because he was an at-will employee and because there was no federal statute directly covering his employment. Id. at 1360. The court held that the state had a strong interest in preventing criminal actions such as embezzlement and that the LMRDA supported the plaintiff's position because it expressly "saves both state criminal actions and state-imposed responsibilities of union officers" in 29 U.S.C. 523(a) and 29 U.S.C. 524. Id. at 1361. The court stated that there was an exception to preemption when "a union employee bases a wrongful discharge action on allegations that he was fired for refusing to violate state law. ...." Id. at 1362 (emphasis added). The court further determined that, because the plaintiff alleged that he was fired for refusing to illegally alter minutes and not for political reasons, the federal interest in union democracy recognized in Finnegan was not implicated and the state cause of action would not interfere with that statutory purpose. Id. at 1362.

Similarly, in Montoya v. Local Union III of the Int'l Brotherhood of Electrical Workers, 755 P.2d 1221, 1223 (Colo.App., 1988), the plaintiff claimed that he was discharged from his position as a union business manager for uncovering illegal union practices and refusing to vote for the candidate that the business manager favored. Because the court concluded that the business manager could hire and fire his representatives and assistants at any time and discharge would not affect the plaintiff's union membership, the plaintiff's wrongful discharge claims generally conflicted with LMRDA and were preempted. Id. at 1223-1224. However, the court held that the doctrine of preemption did not bar the plaintiff's wrongful discharge claim "insofar as he allege[d] that he was discharged because he refused to aid [the business manager] in his alleged criminal misuse of union funds." Id. at 1224.

Whereas Bloom and Montoya involved discharges for the plaintiffs' alleged refusal to commit or aid in committing a crime, plaintiff here was terminated for failing to abide by legitimate policies, such as itinerary and mileage recording, designed to comply with the law.3

Finally, we consider the decision in Ardingo v. Local 951, United Food Commercial Workers Union, 333 Fed. Appx. 929 (6th Cir.2009). In Ardingo, the Sixth Circuit held that the LMRDA did not preempt a wrongful-termination claim almost identical to the claim at issue in this case. For the reasons stated below, we do not follow Ardingo.4

The plaintiff in Ardingo was a business agent for the same union that employed plaintiff in this case. The same policy requiring that employees be terminated only for just cause was in force. Id. at 931. After rumors circulated that Ardingo might mount a campaign against the union's president, the union president insinuated that Ardingo was a "pipeline to the Department of Labor." Id. Thereafter, Ardingo cooperated with a Department of Labor investigation concerning financial irregularities in the union and then testified before a grand jury concerning the same issues. Id. at 931. Ardingo was then reassigned in rapid succession to jobs in other states, ostensibly to assist with union organizing campaigns. Id. at 931-932. But the union was also experiencing substantial declines in revenue. Id. Later, Ardingo, who earned $100,000 a year and had less seniority than other similarly situated employees, was one of 10 employees who were discharged. Id. The union president testified that the discharge of Ardingo was for economic and other reasons. Ardingo argued that the economic reasons were not the real reason for his discharge, but a mere pretext, and that his discharge was retaliatory and in violation of the just-cause policy. Id. at 932.

The Sixth Circuit held that the LMRDA did not preempt Ardingo's state-law claim of discharge in violation of the just-cause policy. Ardingo, 333 Fed.Appx. at 933-36. The court reasoned that "[t]he fact that the LMRDA does not provide a cause of action to union employees who have been fired for political reasons does not mean that state law could never restrict a union leader's discretion to terminate a union employee." Id. at 936, citing Bloom, 783 F.2d at 1360-1362. The court further reasoned that "[s]uch a question was not even before the Finnegan Court. Therefore, it would be wrong to say that Finnegan stands for the proposition that the LMRDA gives union officials unlimited discretion in employment matters." Ardingo, 333 Fed.Appx. at 936.

We disagree with Ardingo's reasoning and decline to follow it. While Finnegan did not absolutely decide the question whether this exact claim is preempted by the LMRDA, Finnegan was clear that at least one of the purposes of the LMRDA is to promote union democracy and ensure that the representatives whom union members have elected are able to carry out the policies on which they were elected. See Finnegan, 456 U.S. at 442, 102 S.Ct. 1867 ("[I]n enacting Title I of the Act, Congress simply was not concerned with perpetuating appointed union employees in office at the expense of an elected president's freedom to choose his own staff. Rather, its concerns were with promoting union democracy...."). Preemption applies when a state-law claim conflicts with the purposes of federal law. Ambassador Bridge, 481 Mich, at 36, 748 N.W.2d 221. We believe that, in this case, plaintiff's claim would conflict with the efforts of elected union officials to implement the policies on which they were elected and, in that way, interfere with one of the purposes of the LMRDA.

IV

In sum, the cases finding preemption under similar circumstances are more numerous, more factually analogous, and more persuasive than the cases finding no preemption by the LMRDA of similar wrongful-discharge claims. The cases finding preemption of state common-law claims by the LMRDA illustrate that wrongful-discharge claims brought by discharged or demoted union employees who were in policymaking or policy-implementing positions would undermine one of the purposes and goals of the LMRDA, namely, the purpose and goal of protecting democratic processes in union leadership. If union members cannot choose their leaders, or if the chosen leaders cannot implement the policies they were elected to implement, then the rights of union members (as represented by their elected leaders) would be thwarted, or at least diminished. Accordingly, the circuit court correctly held that the LMRDA preempts plaintiff's claim of wrongful discharge in violation of the union's just-cause policy and, because of federal preemption, the circuit court correctly held that it lacked subject-matter jurisdiction to hear that claim. Ryan, 454 Mich. at 27, 557 N.W.2d 541.5

Affirmed. Defendant, being the prevailing party, may tax costs pursuant to MCR 7.219.

DAVIS, J., concurred.

BECKERING, P.J. (dissenting).

Plaintiff claims that his employment was terminated in violation of defendant's just-cause policy. I write separately because I respectfully disagree with the majority's conclusion that plaintiff's wrongful-discharge claim is preempted by the Labor-Management Reporting and Disclosure Act (LMRDA), 29 U.S.C. 401 et seq. I would vacate the trial court's orders granting summary disposition to defendant and denying plaintiff's motion for reconsideration.

The trial court granted defendant summary disposition under MCR 2.116(C)(4), concluding that it lacked subject-matter jurisdiction. As indicated by the majority, this Court reviews de novo a trial court's decision on a motion for summary disposition, Maiden v. Rozwood, 461 Mich. 109, 118, 597 N.W.2d 817 (1999), and reviews for an abuse of discretion its decision on a motion for reconsideration, Churchman v. Rickerson, 240 Mich.App. 223, 233, 611 N.W.2d 333 (2000). Whether a trial court has subject-matter jurisdiction is a question of law, which this Court reviews de novo. Fisher v. Belcher, 269 Mich.App. 247, 252-253, 713 N.W.2d 6 (2005).

"Where the principles of federal preemption apply, state courts are deprived of subject matter jurisdiction." Ryan v. Brunswick Corp., 454 Mich. 20, 27, 557 N.W.2d 541 (1997), overruled in part on other grounds Sprietsma v. Mercury Marine, 537 U.S. 51, 123 S.Ct. 518, 154 L.Ed.2d 466 (2002). In the absence of express preemption, federal preemption may be implied in the form of conflict or field preemption. Ryan, 454 Mich. at 28, 557 N.W.2d 541. The majority concludes here that plaintiff's wrongful-discharge claim under state law conflicts with the LMRDA and is, therefore, "conflict-preempted." "Conflict preemption acts to preempt state law to the extent that it is in direct conflict with federal law or with the purposes and objectives of Congress." Id.

In Finnegan v. Leu, 456 U.S. 431, 441, 102 S.Ct. 1867, 72 L.Ed.2d 239 (1982), the United States Supreme Court stated that when the LMRDA was enacted, its "overriding objective was to ensure that unions would be democratically governed, and responsive to the will of the union membership as expressed in open, periodic elections." The Court further stated that "the ability of an elected union president to select his own administrators is an integral part of ensuring a union administration's responsiveness to the mandate of the union election." Id. According to the majority in this case, allowing plaintiff's state claim for wrongful discharge to proceed would conflict with the LMRDA's purpose of ensuring union democracy and elected union officials' authority to select staff members.

In Ardingo v. Local 951, United Food & Commercial Workers Union, 333 Fed. Appx. 929, 934 (6th Cir.2009), however, the court concluded that "[t]here is no danger that [the LMRDA's] objective will be interfered with by a lawsuit that seeks to vindicate an employee's rights under a just-cause employment contract." Although this Court is not required to follow decisions of a United States court of appeals, Abela v. Gen. Motors Corp., 469 Mich. 603, 606, 677 N.W.2d 325 (2004), and Ardingo is unpublished, I find the Ardingo court's reasoning persuasive. See id. at 607, 677 N.W.2d 325. Like Ardingo, this case presents a unique set of facts in that plaintiff is suing to enforce his contractual rights under his just-cause employment contract with defendant. None of the out-of-state cases relied on by the majority involve a just-cause contract provision. As noted by the Ardingo court, "when a union chooses to offer a just-cause employment contract to an employee, there is nothing in Finnegan or the LMRDA that would prevent that contract from being enforced." Ardingo, 333 Fed.Appx. at 936. Finnegan does not stand for the proposition "that state law could never restrict a union leader's discretion to terminate a union employee." Id., citing Bloom v. Gen. Truck Drivers, Office, Food & Warehouse Union, Local 952, 783 F.2d 1356, 1360-1362 (C.A. 9, 1986) (holding that a wrongful-discharge claim was not preempted by the LMRDA when a business agent claimed to have been discharged for refusing to violate state law). While the majority is correct that the LMRDA was enacted to ensure that unions are democratically governed and that elected union officials have the ability to select staff members, and, in that way, respond "to the mandate of the union election," Finnegan, 456 U.S. at 441, 102 S.Ct. 1867, democratically elected union officials may choose to offer an employee a just-cause employment contract, omit a just-cause provision from an employment contract, or tailor such a provision by, for example, defining the term "just cause" in the contract. Thus, enforcing a union's just-cause policy does not conflict with the LMRDA's objective of ensuring union democracy. To hold otherwise would permit unions to offer employment contracts with just-cause provisions that the employees have no ability to enforce, at least in state court, rendering the provisions virtually meaningless.1

I would hold that plaintiff's wrongful-discharge claim is not preempted by the LMRDA because his claim does not directly conflict with the act or with any of its purposes or objectives, see Ryan, 454 Mich, at 28, 557 N.W.2d 541, and would vacate the trial court's orders granting summary disposition to defendant on the basis of preemption and denying plaintiff's motion for reconsideration.2