Flight Options, LLC v. International Brotherhood of Teamsters, Local 1108
873 F.3d 540
6th Cir.2017Background
- Flight Options agreed to acquire Flexjet; the airlines and the pilots’ union (Teamsters Local 1108) must integrate two pilot groups under one collective-bargaining agreement (CBA).
- Flight Options and the union had an existing CBA with Section 1.5(c)(4) requiring modification to "permit the integration" of new pilots and providing arbitration if parties reach an impasse within nine months.
- After the merger the CBA became "amendable" under the Railway Labor Act (RLA), and the union served notice under RLA §6 proposing broad changes to pay and work rules for the combined pilot group.
- The airlines focused on Section 1.5(c)(4) integration negotiations, arguing Flexjet pilots are not yet governed by the existing CBA; the union insisted Section 6 bargaining over broader terms proceed immediately.
- The district court granted a preliminary injunction ordering the airlines to bargain the union’s Section 6 proposals in good faith; the airlines appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the dispute over the order/scope of bargaining is a "major" RLA dispute (court action permitted) or a "minor" dispute (arbitrable) | Union: Serving §6 notice makes this a major dispute requiring immediate §6 bargaining; court may enjoin refusal to bargain | Airlines: CBA’s Section 1.5(c)(4) arguably requires integrating Flexjet pilots before broader §6 bargaining; dispute is minor and must be sent to arbitration | Held: Dispute is minor — airlines’ interpretation is "arguably justified," so issue belongs to arbitration; preliminary injunction vacated |
| Whether portions of the district court’s order (e.g., factual characterizations of corporate relationships or comments on §1.5(c)(4)) are impermissible advisory opinions subject to reversal | Airlines: District court made advisory statements violating Article III; ask to strike them | Union: Order resolved live controversy; statements not reversible as advisory dictum | Held: Declined to strike; appellate court will not parse or revise district court prose sentence-by-sentence; no Article III problem shown |
| Whether the district court erred in finding bad-faith bargaining over a Voluntary Separation Program (VSP) | Airlines: Challenge the bad-faith finding | Union: District court’s finding sustained | Held: Issue is moot because parties settled the VSP dispute; appellate court did not reach merits |
Key Cases Cited
- Consol. Rail Corp. v. Ry. Labor Execs’ Ass’n, 491 U.S. 299 (1989) (distinguishes RLA major and minor dispute procedures)
- Elgin, J. & E. Ry. Co. v. Burley, 325 U.S. 711 (1945) (defines "major" disputes as changes creating future rights)
- CSX Transp., Inc. v. United Transp. Union, 395 F.3d 365 (6th Cir. 2005) (party claiming a minor dispute bears relatively light burden to show its action is arguably justified by the CBA)
- Emswiler v. CSX Transp., Inc., 691 F.3d 782 (6th Cir. 2012) (RLA procedural framework governs carrier-union disputes)
- Airline Prof’ls Ass’n, Teamster Local Union 1224 v. ABX Air, Inc., 400 F.3d 411 (6th Cir. 2005) (contract language can support delaying §6 bargaining if reasonably read to permit delay)