Flight Options v. International Brotherhood of Teamsters, No. 16-3606 (6th Cir. 2017)Annotate this Case
The Unions represents the pilots of merged airlines Flight Options and Flexjet. Flight Options and its pilots have had a collective bargaining agreement since 2010, while Flexjet’s pilots are newly unionized and are not yet party to a CBA. The parties dispute whether the integration of the pilot groups’ seniority lists (ISL) is solely a Union matter, so that the airlines must accept the Union's list or whether the airlines should have been allowed to participate in negotiating the list. The 2010 CBA governs the creation of the ISL when Flight Options acquires another carrier. The district court, acting under the Railway Labor Act (RLA), 45 U.S.C. 152, entered a preliminary injunction ordering the airlines to accept the Union’s ISL. On appeal, the airlines argued that the dispute was “minor” and subject to exclusive arbitral jurisdiction. The Sixth Circuit affirmed in part. The 2010 CBA does not arguably justify the airlines' assertion that they have a right to participate in the ISL process; the dispute is major. The district court properly enjoined the airlines to honor the express terms of the CBA, but those terms provide that if the airlines refuse to accept the Union’s proffered ISL, the Union may invoke an expedited grievance-arbitration process, which uniquely applies to such disputes. The court ordered modification of the injunction accordingly.