Krakowski v. Allied Pilots Ass'n, No. 19-1816 (8th Cir. 2020)
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Plaintiff filed suit against Allied Pilots in state court for conversion and unjust enrichment, arguing that he was entitled to keep his whole profit sharing payment rather than give some of it to the union for "dues." The union removed to federal court, contending that plaintiff's claims are preempted by the Railway Labor Act (RLA). The district court held that state law claims fell away due to preemption and the federal claims did not survive summary judgment.
The Eighth Circuit reversed and held that the district court erred by relying on the complete-preemption doctrine, finding that the RLA wholly displaced plaintiff's state law claims. In this case, the RLA does not require disputes between an employee and a union to be heard by an adjustment board, so there is no federal cause of action at all, much less an exclusive one. Accordingly, the court vacated the district court's judgment and instructed the district court, on remand, to return this case to state court.
Court Description: [Stras, Author, with Benton and Grasz, Circuit Judges] Civil case - Civil procedure. The district court erred in finding the Railway Labor Act wholly displaced plaintiff's state law conversion and unjust-enrichment claims with respect to his argument that he was entitled to a return of a union dues deduction from his profit sharing payment; the Railway Labor Act does not require disputes between an employee and a union to be heard by an adjustment board, so there is no federal cause of action here, much less an exclusive one; remanded with directions to the district court to remand the case to state court.
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