Flight Options, LLC v. International Brotherhood of Teamsters, Local 1108
863 F.3d 529
| 6th Cir. | 2017Background
- Flight Options (unionized under a 2010 CBA) acquired Flexjet (previously nonunion); the Teamsters were certified to represent the combined pilot groups.
- Section 1.5(c)(1) of the 2010 CBA provides that if the Teamsters represent both groups, the integrated seniority list (ISL) is to be created pursuant to "Teamsters Merger Policy," and the Company "shall accept" the ISL; otherwise Allegheny-Mohawk procedures apply.
- The Union formed two merger committees (FOMC and FXMC) and proffered an ISL using a longevity-based methodology; Flight Options’ management (Silvestro/Ricci) refused to accept the list, asserting McCaskill-Bond/Allegheny-Mohawk required carriers’ participation and that no Teamsters Merger Policy existed.
- The Union filed a grievance and sought expedited arbitration under the CBA; the Carriers sued for declaratory relief and a preliminary injunction arguing the dispute was a minor one requiring bargaining and carrier participation under McCaskill-Bond.
- The district court held the dispute was a major RLA dispute, found the Union’s ISL process satisfied McCaskill-Bond, and preliminarily enjoined the Carriers to accept the ISL; the Sixth Circuit affirmed jurisdiction but modified the injunction to require either acceptance of the ISL or submission to the CBA’s expedited arbitration.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ISL integration question is a "major" or "minor" dispute under the RLA | Union: CBA §1.5(c)(1) commits ISL creation to the Teamsters; carrier must accept proffered ISL; dispute is major permitting district-court relief to enforce status quo | Carriers: Their refusal is arguably justified by the CBA because (they claim) no Teamsters Merger Policy exists and McCaskill-Bond/Allegheny-Mohawk requires carrier participation; thus dispute is minor and for arbitration | Held major: CBA language unambiguously commits ISL creation to the Union; carriers’ contractual claim is not arguably justified, so federal court jurisdiction proper |
| Whether McCaskill-Bond/Allegheny-Mohawk independently obligates carriers to participate in integration despite CBA | Carriers: Statute requires fair and equitable integration and may require collective bargaining with carriers | Union: When same collective-bargaining agent represents both crafts, the union’s internal policies supersede McCaskill-Bond; where CBA governs integration its terms control | Held: CBA governs; McCaskill-Bond does not displace the CBA or give carriers a distinct statutory duty here |
| Whether the Union’s unwritten merger policy and the merger committees satisfied the contract’s requirement for a Teamsters merger policy | Union: An unwritten internal merger policy (appointment of autonomous committees under Union rules) suffices | Carriers: No standalone Teamsters Merger Policy exists; therefore the contract’s specified process is absent | Held: The Union’s procedures for appointing committees constituted its merger policy for §1.5(c)(1); the process and ISL were fair and equitable |
| Proper remedy where carrier refuses to accept proffered ISL | Union: District court may order carriers to accept ISL to maintain status quo | Carriers: Should be allowed to negotiate/bargain over ISL or proceed under MC-B procedures; dispute is for arbitration | Held: Carriers must either accept the Union-proffered ISL or submit to the CBA’s expedited grievance arbitration (district court injunction modified to preserve contractual remedy) |
Key Cases Cited
- Consol. Rail Corp. v. Ry. Labor Execs.’ Ass’n, 491 U.S. 299 (1989) (distinguishing major and minor RLA disputes; major disputes seek to create new contractual rights)
- Wheeling & Lake Erie Ry. Co. v. Brotherhood of Locomotive Engineers & Trainmen, 789 F.3d 681 (6th Cir. 2015) (contractual claims that are facially insubstantial render disputes major)
- Airline Prof’ls Ass’n v. ABX Air, Inc., 400 F.3d 411 (6th Cir. 2005) (dispute is minor if employer action is arguably justified by the CBA)
- Elgin, J. & E.R. Co. v. Burley, 325 U.S. 711 (1945) (foundational delineation of major vs. minor RLA disputes)
- Detroit & Toledo Shore Line R. Co. v. United Transportation Union, 396 U.S. 142 (1969) (status quo preservation and bargaining/mediation procedures in major disputes)
- Chicago & North Western Ry. Co. v. United Transportation Union, 402 U.S. 570 (1971) (permitting labor injunctions to enforce duty to make and maintain agreements)
- Steele v. Louisville & Nashville R.R. Co., 323 U.S. 192 (1944) (union duty of fair representation)