Brotherhood of Railroad Signalmen v. National Railroad Passenger Corporation, No. 23-7018 (D.C. Cir. 2024)
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In 2017, the Brotherhood of Railroad Signalmen (the Union) initiated proceedings against the National Railroad Passenger Corporation (Amtrak) in federal district court. The Union contested Amtrak’s refusal to use Union-represented signalmen in a newly acquired building. The district court sent the case to mandatory arbitration under the Railway Labor Act (RLA). The National Railroad Adjustment Board (the Board) dismissed the claim, stating it lacked jurisdiction because the Union was seeking relief based on hypothetical facts.
The district court vacated the Board’s award and remanded for further proceedings, holding that the Board did not consider or interpret the parties’ agreement. Amtrak appealed, arguing that the award should be upheld under the highly deferential judicial standard of review because it was at least arguably based on rail industry common law and Rule 56 of the collective bargaining agreement.
The United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s decision. The court found that the Board’s award should be vacated because it did not decide the dispute based on the parties’ contract. Instead, the Board relied on legal principles governing federal courts’ subject-matter jurisdiction, which are outside the scope of the Board’s authority. The court emphasized that the Board must interpret the contract and cannot base its decisions on external legal principles unrelated to the contract. The case was remanded to the district court with instructions to remand to the National Railroad Adjustment Board for proceedings consistent with the opinion.
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