Brotherhood of Maint v. Union Pacific

Citation: Not availableDocket: 03-3083

Court: Court of Appeals for the Seventh Circuit; February 11, 2004; Federal Appellate Court

Original Court Document: View Document

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The Brotherhood of Maintenance of Way Employees (BMWE) filed a lawsuit against Union Pacific Railroad Company (UP), claiming UP violated the Railway Labor Act (RLA) by not referring certain disputes to expedited arbitration. UP countered by seeking an injunction to prevent BMWE from striking or engaging in other self-help actions. The district court denied BMWE’s request for declaratory relief and granted UP’s motion for a preliminary injunction. BMWE contended that the court misapplied the RLA and that the injunction was improper under the Norris-LaGuardia Act. The appellate court affirmed the district court's judgment.

BMWE and UP are bound by a collective bargaining agreement (CBA), which mandates that UP hire BMWE members for all related work, with specific exceptions. In late 2001, UP informed BMWE of its intent to contract out work for a new facility in Rochelle, Illinois, citing a CBA exception. BMWE contested this and threatened to strike. A subsequent settlement allowed UP to use contract workers while ensuring that senior BMWE employees could be hired if they requested work on the project. 

However, disputes soon arose over UP's hiring practices under the settlement agreement, with BMWE alleging UP hired fewer workers than required. UP maintained that it was only obligated to provide a number of positions equal to contractors and not to hire all eligible BMWE workers. BMWE sought to resolve these issues through expedited arbitration under the RLA. UP agreed to arbitration but declined the expedited option, suggesting the standard CBA procedures, which BMWE rejected due to their lengthy timeline. Despite this, BMWE filed individual claims under the CBA's procedures, which UP was willing to arbitrate, but BMWE refused, arguing that individual arbitration would not clarify the settlement agreement's terms.

BMWE declined to arbitrate claims due to concerns about identifying claimants and potential loss of health insurance and seniority rights. Subsequently, BMWE sought a declaratory judgment in district court, asserting that the RLA required UP to engage in expedited arbitration. UP countered with a request for a preliminary injunction against a potential BMWE strike. The magistrate judge denied BMWE's motion and granted UP's injunction, leading BMWE to appeal both rulings.

Under the RLA, minor disputes regarding railway labor agreements must be resolved by arbitrators, while major disputes require a lengthy bargaining and mediation process. The terms "minor" and "major" are legal definitions within RLA case law. Minor disputes involve the interpretation of existing agreements, while major disputes arise when employer claims are deemed frivolous. In this case, the dispute over the settlement agreement is classified as minor, and UP’s interpretation, although contestable, does not appear frivolous enough to bypass major dispute procedures. Consequently, the district court lacked jurisdiction over BMWE's claim regarding UP’s failure to participate in expedited arbitration, justifying the denial of BMWE's motion for declaratory relief.

Regarding the preliminary injunction, appeals are assessed based on the district court's factual findings, evaluation of injunction factors, and legal interpretations. BMWE's appeal focuses on the alleged misinterpretation of the law rather than the balancing of injunction factors. While the adjustment board holds jurisdiction over minor disputes, district courts may intervene to prevent strikes in such cases.

BMWE contends that the district court incorrectly granted UP a preliminary injunction, arguing two main points. First, BMWE claims that UP's refusal to engage in expedited arbitration constitutes a breach of its obligation under Section 2 First of the Railway Labor Act (RLA) to make "every reasonable effort" to resolve disputes. BMWE argues that UP rejected the most efficient arbitration method for their disagreement. Second, BMWE asserts that the Norris-LaGuardia Act (NLGA) restricts the district court's jurisdiction to issue an injunction since Section 8 prohibits injunctive relief for parties in labor disputes who do not make reasonable efforts to settle the dispute.

The RLA mandates that carriers and unions must actively seek to resolve disputes to prevent disruptions in commerce. The Supreme Court has likened the duties under the RLA to the good faith bargaining requirements of the National Labor Relations Act. BMWE maintains that UP's refusal to expedite arbitration violates both the RLA and NLGA, warranting denial of the injunction.

The court, however, disagrees with BMWE's stance. It clarifies that while UP is required to negotiate in good faith, there is no legal obligation for UP to agree to the fastest arbitration method. The court draws parallels to a previous case where a union's argument against an injunction was rejected on similar grounds, emphasizing that the law demands reasonable efforts, not every conceivable action. 

Despite BMWE's preference for expedited arbitration, the court notes that UP's compliance would exceed the reasonable effort threshold. The parties had previously agreed to a specific arbitration procedure, and BMWE's dissatisfaction with the pace does not justify imposing a new resolution method on UP. The court finds no evidence of UP acting in bad faith and acknowledges that UP has offered to arbitrate claims in accordance with the collective bargaining agreement (CBA). Therefore, UP’s refusal to expedite arbitration does not breach the RLA, and the NLGA does not prevent UP from obtaining an injunction. The district court's decision is upheld, affirming BMWE's obligation under the RLA to avoid interrupting commerce.