Sturge v. Northwest Airlines, Inc.
658 F.3d 832
| 8th Cir. | 2011Background
- Sturge, employed by Northwest Airlines since 1989 as a first officer, was terminated for cause on October 31, 2003 after admitting marijuana possession under the company drug policy.
- He had applied for disability retirement benefits under the Pension Plan, with benefits processing continuing after termination, but he lost several post-termination benefits due to the for-cause dismissal.
- Northwest approved Sturge's disability retirement date as October 31, 2003, yet determined he was ineligible for seniority accrual, return-to-work rights, pass privileges, and company-paid medical insurance due to termination timing.
- Sturge sued Northwest in 2005 under ERISA § 510 alleging retaliation and interference with rights to disability retirement benefits; case was administratively terminated due to Northwest's bankruptcy and later reopened in 2008.
- The district court granted summary judgment for Northwest, and both parties appealed to the Eighth Circuit.
- The court addressed whether the ERISA claim falls under the RLA's minor-dispute framework and whether the record could support a jury finding of retaliatory motive or improper interference.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| RLA jurisdiction over ERISA claim | ERISA claim not a minor dispute; independent of CBA interpretation. | ERISA claim is a minor dispute requiring RLA arbitration. | RLA jurisdiction proper; claims involve factual conduct and motives, not interpretation of CBA. |
| Causation under §510 retaliation/interference | Termination was retaliatory for applying for disability retirement. | Termination was for drug policy violation; no causal link to benefits application. | No genuine causal issue; termination for drug policy violation independently justified. |
| Comparator evidence and motive | Brewbaker similarly situated; comparator supports improper motive. | Brewbaker not similarly situated; not probative of Sturge's claim. | Brewbaker not sufficiently similarly situated; comparator evidence fails to prove motive. |
Key Cases Cited
- Hawaiian Airlines, Inc. v. Norris, 512 U.S. 246 (1994) (RLA major/minor dispute framework; exclusive arbitration for minor disputes)
- Lingle v. Norge Div. of Magic Chef, Inc., 486 U.S. 399 (1988) (purely factual questions about conduct may not require CBA interpretation)
- Deneen v. Nw. Airlines, Inc., 132 F.3d 431 (8th Cir.1998) (RLA preclusion for minor disputes; not all labor claims fall within RLA)
- Koons v. Aventis Pharmaceuticals, Inc., 367 F.3d 768 (8th Cir.2004) (similarly situated standard for determining admissibility of comparator evidence)
- Hastings v. Wilson, 516 F.3d 1055 (8th Cir.2008) (RLA preemption/preclusion for ERISA claims involving minor disputes)
- Carmona v. Southwest Airlines Co., 536 F.3d 344 (5th Cir.2008) (distinction between contract interpretation and application of contract terms)
- Consolidated Rail Corp. v. Railway Labor Executives' Ass'n, 491 U.S. 299 (1989) (line between major and minor disputes; 'arguably justified' standard limited to categorization)
- Freeman v. Ace Tel. Ass'n, 467 F.3d 695 (8th Cir.2006) (independent cause arises from policy violation; timing matters for causation)
- Kiel v. Select Artificials, Inc., 169 F.3d 1131 (8th Cir.1999) (evidence of motive and temporal proximity in ERISA claims)
- Taggart v. Trans World Airlines, Inc., 40 F.3d 269 (8th Cir.1994) (major disputes; remedial framework under RLA)