Beckington v. American Airlines, Inc., No. 18-15648 (9th Cir. 2019)Annotate this Case
The Ninth Circuit affirmed the district court's dismissal of an action brought by airline pilots, seeking damages under the Railway Labor Act (RLA). Plaintiffs alleged that their employer colluded with a union in the union's breach of its duty of fair representation.
The panel held that, under the RLA, employees can hold their union liable for breaching its duty of fair representation during collective bargaining. The panel held, however, that the RLA does not support the imposition of liability on an employer solely for its "collusion" in the union's breach of duty. In this case, plaintiffs did not claim that their employer breached its own obligations under a collective bargaining agreement. Rather, the only identifiable breach in this case was USAPA's breach of its duty of fair representation.