FCA US LLC v. The International Union, United Automobile, Aerospace and Agricultural Implement Workers of America
3:24-cv-01698
D. Or.May 19, 2025Background
- FCA US LLC filed a series of lawsuits against the UAW and its local unions in multiple districts (including Oregon), all involving disputes over the parties' collective bargaining agreement (CBA) and a related document known as "Letter 311."
- The CBA prohibits strikes before exhausting the grievance process, and Letter 311 concerns FCA's investment promises; FCA alleges UAW engaged in misinformation and improper strike threats regarding these.
- The first lawsuit was filed in the Central District of California, followed by an identical lawsuit in Oregon, and others in various states.
- The California action was dismissed as unripe, and FCA filed an appeal to the Ninth Circuit.
- FCA sought to consolidate the cases via the Judicial Panel on Multidistrict Litigation (JPML), but the JPML denied centralization.
- In Oregon, UAW moved to dismiss or stay the suit under the first-to-file rule pending the Ninth Circuit appeal; the court stayed the action rather than dismissing it.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicability of first-to-file rule | Not applicable due to intervening events (CA case dismissed) | Rule applies—CA action filed first with same parties/issues | Rule applies—factors satisfied; CA action controls |
| Similarity of parties | Parties not identical in every case | Substantial similarity suffices | Substantially similar—requirements met |
| Similarity of issues | Issues differ due to local unions' involvement | Issues substantially the same—focus on CBA/Letter 311 | Issues are substantially similar/legal overlap |
| Stay vs. Dismissal | Favor stay to preserve claims pending appeal | Seek dismissal or, in alternative, a stay | Stay granted; dismissal not appropriate during appeal |
Key Cases Cited
- Kohn Law Grp., Inc. v. Auto Parts Mfg. Miss., Inc., 787 F.3d 1237 (9th Cir. 2015) (establishes the first-to-file rule factors and flexibility)
- Alltrade, Inc. v. Uniweld Prods., Inc., 946 F.2d 622 (9th Cir. 1991) (first-to-file rule is discretionary and must advance efficiency/comity)
- Pacesetter Sys., Inc. v. Medtronic, Inc., 678 F.2d 93 (9th Cir. 1982) (rejects mechanical application of first-to-file rule)
- Harris County v. CarMax Auto Superstores Inc., 177 F.3d 306 (5th Cir. 1999) (first-to-file does not require identical parties; substantial similarity is enough)