Beckington v. American Airlines, Inc., No. 18-15648 (9th Cir. 2019)
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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.
Court Description: Labor Law. The panel affirmed the district court’s dismissal for failure to state a claim of an action brought by airline pilots, seeking damages under the Railway Labor Act against their employer for allegedly “colluding” with a union in the union’s breach of its duty of fair representation. In 2005, US Airways and America West Airlines merged to form a single carrier, which kept the name US Airways. The Air Line Pilots Association represented both the US Airways Pilots (the “East Pilots”) and the America West pilots (the “West Pilots”). The East Pilots and the West Pilots engaged in a seniority dispute that went to arbitration. The East Pilots formed a new union, the US Airline Pilots Association (“USAPA”), which became the bargaining representative for all the pilots. In Addington I, a group of West Pilots alleged that USAPA breached its duty of fair representation by failing to pursue implementation of the arbitration award, known as the “Nicolau Award.” In Addington II, US Airways sued USAPA and the West Pilots, seeking declaratory relief. In anticipation of a merger between US Airways and American Airlines, the two airlines, USAPA, and the union for American’s pilots negotiated a memorandum of understanding (“MOU”) addressing pilot seniority. In Addington III, a group of West Pilots alleged that USAPA breached its duty of fair representation by including in the MOU Paragraph 10(h), which abandoned the BECKINGTON V. AMERICAN AIRLINES 3 Nicolau Award. The court of appeals reversed the district court’s judgment after trial in part, holding that USAPA breached its duty of fair representation by inserting Paragraph 10(h) into the MOU. In arbitration pursuant to the MOU, the arbitration panel issued a decision declining to implement the Nicolau Award and using a different methodology for integrating the pilots’ seniority lists. Former West Pilots filed Addington IV, seeking damages under the Railway Labor Act for US Airways’s “collusion” in USAPA’s breach of its duty of fair representation. Affirming the district court’s dismissal, and disagreeing with the Seventh Circuit, the panel held that employees aggrieved by a union’s breach of its duty of fair representation during collective bargaining cannot sue their employer for “colluding” in the union’s breach. The panel concluded that nothing in the Railway Labor Act’s text or collective bargaining framework supported expansion of the doctrine that a union owes its constituents a duty of fair representation. The panel held that the pilots’ suit was different from a hybrid suit, in which employees sue both their employer and their union, because the pilots made no allegation that their employer breached its own obligations under a collective bargaining agreement. 4 BECKINGTON V. AMERICAN AIRLINES
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