Flight Options, LLC, et al. v. Int’l Bhd. of Teamsters, Local 1108, et al., No. 17-3188 (THAPAR, Sutton, Donald).
This is one of several appeals stemming out of a merger between Flight Operations and Flexjet. At issue in this appeal was how to integrate the pilots under one collective-bargaining agreement. The existing collective-bargaining agreement became “amendable” under the Railway Labor Act shortly after the airlines merged, allowing either party to propose broad changes affecting the pilots’ rates of pay and working conditions. The airlines argue that the negotiations under the agreement and the negotiations regarding the proposals should take place at the same time, while the union argued that the airlines should be required to bargain the proposals in good faith first. The union applied for a preliminary injunction, which the district court granted. The airlines appealed.
The Sixth Circuit reversed, vacating the preliminary injunction and remanding the case. Airlines and their unions must resolve their disputes consistent with the procedures in the Railway Labor Act. The Act provides two procedural tracks: one for major disputes—those that concern the acquisition of rights for the future—and one for minor disputes, which arise from disagreements about how an existing agreement applies to a particular situation. In the case of minor disputes, the parties are required to submit to binding arbitration and the court has no role unless asked to review the arbitrator’s decision.
The district court found that the dispute about the order of negotiations was major, but the Sixth Circuit disagreed, reasoning that “[a] dispute can be minor even if it affects the parties’ obligations under [the Railway Act’s “amendable” section]. The proper inquiry is whether the existing collective-bargaining agreement controls the controversy.” The argument at issue involved the interpretation of the existing agreement, and the plain language of the agreement implied that the airlines did not have to bargain over proposals involving all the pilots of the combined airlines until a fully merged agreement was reached, and therefore the Court held that the union failed to show that the dispute was major.