Intl Assn of Sheet Metal, Air, Rail & Trans v. Iowa Northern Railway Company, No. 21-2608 (8th Cir. 2022)
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Iowa Northern Railway Company (“Iowa Northern”) and the International Association of Sheet Metal, Air, Rail and Transportation Workers (the “Union”) are both parties to a Collective Bargaining Agreement (“CBA”) that is subject to the Railway Labor Act (“RLA”). In 2019, Iowa Northern offered to increase the pay of unionized Train and Engine employees to $300 to recruit additional employees. The Union members rejected the pay increase. Subsequently, Iowa Northern served a Section 6 notice on the Union, proposing changes to the CBA. When the Union failed to respond, Iowa Northern provide notice it intended to resort to self-help, and then increased the pay rate to $300 per day.
The Union then filed this case, claiming that Iowa Northern violated the RLA by unlawfully resorting to self-help and seeking a preliminary injunction to maintain the status quo prior to the pay-rate changes. The district court denied the Union's request, finding that it did not meet its burden of establishing the likelihood of success on the merits. The Union appealed.
The Eighth Circuit affirmed the district court's denial of a Union's requested preliminary injunction, finding that the Defendant railway operator did not violate the Railway Labor Act when it resorted to self-help. The court explained the Union's "prolonged foot-dragging and refusal to respond on an issue of vital importance to Iowa Northern (and to the Union’s members) raise substantial doubt that the Union’s status quo claim will survive."
Court Description: [Loken, Author, with Gruender and Grasz, Circuit Judges] Civil case - Railway Labor Act. In this action the Union alleged the railroad violated the Act by unlawfully resorting to self-help and setting daily pay rates and ending deduction of union dues; the Union sought a preliminary injunction restoring the status quo; the district court denied the request for injunctive relief on the ground the Union was unlikely to succeed on the merits, and the Union appeals. Held: the district court did not err in concluding the Union was not entitled to injunctive relief. First, the Union's failure to respond to the railroad's Section 6 RLA notice significantly reduced its likelihood of success on the merits; further, the railroad complied with the waiting periods set out in Section 6 before taking any action, thereby satisfying its statutory obligation to give the Union notice of its intent to make the pay change and an opportunity to request National Mediation Board services; there was also a dispute of material fact as to the status of the Union's earlier Section 6 notice, making an injunction inappropriate in the light of the dispute; finally, there was a significant issue as to whether the Union had complied with its duties under Section 8 of the Norris-LaGuardia Act, a necessary prerequisite to district court jurisdiction to grant the status quo injunctive relief the Union sought.
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