Larranaga

MEMORANDUM *

Mark Larranaga and other former employees (“Employees”) of Northwest Public Defenders (“Northwest Defenders”) appeal the district court’s dismissal of their *393 claims. Northwest Defenders cross-appeals the district court’s denial of its request for sanctions. We affirm. Because the parties are familiar with the factual and procedural history of this case, we will not recount it here.

I

The district court did not err in concluding that the Employees’ claims for retroactive back pay and benefits were preempted by the National Labor Relations Act (“NLRA”). 29 U.S.C. § 151 et seq. The NLRA preempts state law claims whenever the underlying activity “arguably” falls within its purview. San Diego Bldg. Trades Council v. Garmon, 359 U.S. 236, 244-45 , 79 S.Ct. 773 , 3 L.Ed.2d 775 (1959). Garmon “stands for the principle that potential, rather than actual conflict between a state law claim and federal labor law is sufficient to require preemption of the state law claim.” Bassette v. Stone Container Corp., 25 F.3d 757, 760 (9th Cir.1994). “[I]f a crucial element of a state court action is identical to an element of an unfair labor practice that is arguably covered by the…