Wolfe v. BNSF Railway Co., No. 12-35054 (9th Cir. 2014)
Annotate this CasePlaintiff filed suit against BNSF, alleging claims under MCA 39-2-703, which governs the liability of a railway for negligent mismanagement. BNSF removed to federal court. On appeal, plaintiff challenged the district court's order granting summary judgment in favor of BNSF. The district court found that plaintiff's claims were preempted by the Railway Labor Act (RLA), 45 U.S.C. 151-88. Applying the Hawaiian Airlines, Inc. v. Norris framework, the court concluded that plaintiff's state claim concerning a collision was not preempted. The right of railway employees to sue on the basis of negligence or mismanagement resulting in termination may be unusual in other jurisdictions, but such a right is undoubtedly recognized in Montana. The court concluded that plaintiff's claim concerning the conduct leading to the collision was independent of the collective bargaining agreement (CBA) and did not require interpretation by the CBA. Therefore, plaintiff's claim was not preempted by the RLA. The court also concluded that BNSF's disciplinary proceedings were not the legal cause of plaintiff's suspension and termination. Consequently, plaintiff's punitive damages claim was reinstated. The court affirmed in part, reversed in part, and remanded.
Court Description: Preemption / Railway Labor Act. The panel affirmed in part and reversed in part the district court’s summary judgment entered in favor of the BNSF Railway Company in a diversity action brought by a railway employee alleging railway mismanagement and misconduct. The plaintiff-employee was working as a track inspector when his hi-rail truck collided head-on with a freight train. After disciplinary proceedings, BNSF dismissed the employee. The employee brought this action after he was reinstated without backpay. The panel affirmed the district court’s ruling that the employee’s state law claim—alleging injury caused by BNSF’s misconduct in employee disciplinary proceedings under the collective bargaining agreement (“CBA”)—was preempted by the federal Railway Labor Act. The panel reversed the district court’s summary judgment on the employee’s state law claim against BNSF concerning BNSF’s alleged negligent mismanagement that resulted in a head- on collision. The panel held that the employee’s claim concerning BNSF’s conduct leading to the collision was independent of the CBA and did not require interpretation of the CBA, and therefore the claim was not preempted by the Railway Labor Act. Finally, the panel reversed the district court’s ruling dismissing Wolfe’s punitive damages claim.
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