Ruben Sanchez v. United Airlines, Inc.
2:25-cv-00489
| C.D. Cal. | Jun 30, 2025Background
- Plaintiff Ruben Sanchez, a longtime United Airlines flight attendant, alleges he was terminated after an investigation into his private, off-duty social media activity and personal religious discussions onboard, following a third-party complaint.
- Sanchez claims his posts and beliefs (Catholic views on marriage and gender) were used as a pretext for his termination, and alleges United targeted him because of his age, religion, and political expression, contrary to company policy.
- The Association of Flight Attendants-Communications Workers of America (the Union) represented Sanchez under a CBA, initially defended him, but later declined to take his grievance to arbitration, allegedly without individualized assessment.
- Sanchez amended his complaint, asserting claims against United for wrongful discharge (Labor Code § 1101, § 98.6), age and religious discrimination (FEHA § 12940), breach of contract, and against the Union for breach of duty of fair representation and FEHA discrimination.
- The Union moved to dismiss, arguing preemption of state claims by federal labor law, insufficient facts for any claim, and that punitive damages are unavailable for the federal claim.
- The court reviewed the motion to dismiss under Rule 12(b)(6), accepting all plaintiff’s allegations as true for the purpose of this motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| FEHA Claims Preempted by Federal Labor Law | FEHA creates duties independent of CBA/federal law; preemption does not apply | Duty of fair representation preempts state discrimination claims under RLA/LMRA | FEHA claim not preempted; can proceed |
| Availability of Punitive Damages | Punitive damages available under FEHA | Not available if only federal duty claim survives; claim should be stricken | Request is proper; claim for punitive damages stands |
| Duty of Fair Representation—Arbitrariness | Union didn’t exercise individualized judgment, acted in perfunctory/arbitrary fashion | Union made a judgment call not to arbitrate; discretionary, not actionable | Sufficiently pled; claim can proceed on arbitrariness |
| Sufficiency of FEHA Discrimination Pleading | Facts (age, religion, comparators) support plausible inference of discrimination | Allegations are conclusory; no plausible showing of discriminatory animus | Sufficient facts pled for age & religious discrimination |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (sets standard for pleading under Rule 12(b)(6))
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for facially sufficient pleadings)
- Conservation Force v. Salazar, 646 F.3d 1240 (9th Cir. 2011) (dismissal when no cognizable legal theory or sufficient facts)
- Vaca v. Sipes, 386 U.S. 171 (1967) (standards governing union’s duty of fair representation)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden shifting in discrimination claims)
- Chuang v. Univ. of Cal. Davis, Bd. of Trs., 225 F.3d 1115 (9th Cir. 2000) (prima facie discrimination under Title VII/FEHA)
- Hawaiian Airlines, Inc. v. Norris, 512 U.S. 246 (1994) (scope of federal preemption under RLA)
- Ford Motor Co. v. Huffman, 345 U.S. 330 (1953) (wide range of reasonableness for union decisions)