Recent Development by Anna Knull
American Eagle Airlines brought an action in federal court seeking review and vacation of an arbitration award reinstating a pilot the airline had terminated. American Eagle fired the pilot, Captain Terry Balser, pursuant to an investigation that revealed several violations of the collective bargaining agreement (CBA) governing the working conditions of pilots employed at American Eagle. On Balser's behalf, the Air Line Pilots Association, International (ALPA) timely informed American Eagle of its intention to invoke the grievance procedures set out in the CBA. Receiving no response from American Eagle, ALPA again wrote to the airline, to which American Eagle responded that Balser and ALPA could consider the grievance to be denied. ALPA timely submitted an appeal to the System Board. The System Board determined that both parties had violated the terms of the CBA—American Eagle by not affording Balser a first step hearing, and Balser by violating company rules and state and federal laws while on the job—and penalized the airline and the pilot.
American Eagle appealed the System Board's decision to the United States District Court for the Northern District of Texas under the Railway Labor Act. In its motion for summary judgment, the airline argued that the System Board's decision did not conform with the CBA, that the decision was beyond the jurisdiction of the System Board, and that the decision violated public policy. The district court granted the motion, finding that once the System Board had found just cause for termination, it could not impose a remedy against the airline for any procedural errors. The district court vacated the arbitration award, holding that the System Board should have upheld Balser's termination, but rejecting American Eagle's argument that the arbitration award violated public policy. ALPA appealed, and American Eagle filed a cross-appeal on the district court's rejection of the public policy issue. Agreeing with the district court's reasoning, the United States Court of Appeals for the Fifth Circuit held: (1) American Eagle's decision not to hold a first step hearing did not violate the terms of the CBA, (2) the district court correctly determined that the System Board implicitly found just cause to terminate Balser, (3) the System Board acted outside its jurisdiction in sanctioning American Eagle, and (4) the district court was correct in vacating the arbitration award. American Eagle Airlines, Inc. v. Air Line Pilots Ass'n, International, 343 F.3d 401, 409-11 (5th Cir. 2003).
About the Author
Anna Knull.
Citation
78 Tul. L. Rev. 2305 (2004)