Palova v. United Airlines
139 F.4th 458
| 5th Cir. | 2025Background
- Anna Palova, a long-tenured United Airlines flight attendant, was terminated in February 2020 for violating a policy against "parking" flight assignments, as defined by the airline's collective bargaining agreement (CBA).
- Palova claims her firing was motivated by age discrimination, arguing that other, younger employees who committed similar infractions were not terminated.
- United Airlines asserts that Palova was terminated solely for violating the CBA, and that Federal and Texas state courts lack jurisdiction over her claims due to the Railway Labor Act (RLA) which governs airline labor disputes.
- The district court granted summary judgment to United, holding that the RLA precluded Palova’s federal age discrimination claim and preempted her state law claim.
- On appeal, the Fifth Circuit reviewed de novo whether Palova’s ADEA and TCHRA claims were precluded or preempted by the RLA, ultimately deciding if the claim could proceed in federal court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the RLA preclude/preempt Palova's age discrimination claims? | Palova argues her claims are based on statutory rights independent of the CBA. | United argues the claims are minor disputes tied to interpretation of the CBA, thus subject to RLA mechanisms. | The RLA does not preclude/preempt the ADEA and TCHRA claims; federal court retains jurisdiction. |
| Was district court’s grant of summary judgment appropriate? | Palova asserts summary judgment was improper as factual disputes exist. | United contends RLA jurisdictional bar justifies summary judgment. | Summary judgment vacated; case remanded for further proceedings on the merits. |
| Does referencing the CBA require RLA adjudication? | Mere reference to CBA is insufficient; discrimination claims are statutory, not contractual. | Disputed facts over CBA (parking) require RLA arbitration. | Reference to CBA is not dispositive; discrimination claims may proceed in federal court. |
| Should Palova's motion to supplement the record be considered? | Palova requests the record be supplemented with evidence of possible age bias. | United does not substantively oppose, but court's prior RLA ruling made the issue moot. | On remand, district court should consider pending evidentiary motions. |
Key Cases Cited
- Hawaiian Airlines, Inc. v. Norris, 512 U.S. 246 (RLA preemption does not extend to purely statutory claims independent of the CBA)
- Trainmen v. Chicago R. & I.R. Co., 353 U.S. 30 (defines major/minor disputes in context of RLA)
- Consol. Rail Corp. v. Ry. Lab. Executives’ Ass’n, 491 U.S. 299 (touchstone for minor dispute is if CBA interpretation conclusively resolves dispute)