Matthew McKinley v. Southwest Airlines Co., 680 F. App'x 522

Plaintiff Matthew McKinley, a former Southwest Airlines employee, sued for unpaid overtime under California Labor Code §§ 510 and 1194.
Southwest moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), arguing the Railway Labor Act (RLA) preempted the state-law claims.
The complaint asserted the right to overtime under state law but alleged that Southwest failed to include various types of remuneration (e.g., non-discretionary incentive pay, shift differentials) in the regular rate.
Those pay components and related rules (shift-trade pay, holiday pay, premiums, starting-time premiums) are addressed in the collective bargaining agreement (CBA).
The district court held resolution would require interpreting the CBA and thus dismissed for RLA preemption; the Ninth Circuit reviewed that decision de novo and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether McKinley’s California overtime claim is preempted by the RLA because it requires interpretation of the CBA	McKinley: his right to overtime is grounded in state law, so the court can apply state law without interpreting the CBA (only "look to" it)	Southwest: resolving which pay elements form the regular rate requires interpreting CBA provisions addressing those pay elements, so the RLA preempts the claim	The court held the claim is RLA-preempted because resolving it requires interpreting the CBA, not merely consulting it

Reid v. Johnson & Johnson, 780 F.3d 952 (9th Cir.) (de novo review of RLA preemption determinations)
Kobold v. Good Samaritan Reg'l Med. Ctr., 832 F.3d 1024 (9th Cir. 2016) (two-step RLA preemption test)
Air Transp. Ass’n of Am. v. City & Cty. of S.F., 266 F.3d 1064 (9th Cir. 2001) (state-law claims requiring CBA interpretation are RLA-preempted)
Lujan v. S. Cal. Gas Co., 96 Cal. App. 4th 1200 (Cal. Ct. App.) (distinguishing cases where the issue is statutory compliance rather than CBA interpretation)