BNSF Railway Co. v. International Association of Sheet Metal, Air, Rail and Transportation Workers, No. 20-10162 (5th Cir. 2020)
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This appeal arose out of a labor dispute between a group of railroad companies and a labor organization representing the railroads' employees (SMART-TD). The railroads filed suit against SMART-TD, alleging that its refusal to bargain over crew consist violated the Railway Labor Act (RLA). The district court issued a permanent injunction requiring SMART-TD to begin negotiating over the crew consist proposals.
The Fifth Circuit vacated the permanent injunction, holding that the district court properly classified the present dispute but that the injunction was not the proper remedy considering the type of dispute. In this case, there are two interrelated, but distinct disputes: the moratorium dispute and the crew consist dispute. The court agreed with the district court that the moratorium dispute is a minor dispute and is therefore subject to compulsory and binding arbitration before the National Railroad Adjustment Board or before an adjustment board established by the employer and the unions representing the employees. Furthermore, the crew consist dispute is major because it involves amending the existing collective bargaining agreements (CBAs). The court deferred the minor moratorium dispute to the exclusive jurisdiction of the board, allowing it to first decide whether SMART-TD is required to bargain, and potentially avoid major dispute procedures and the availability of self-help measures all together.
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