descrybe logo
You are viewing a free summary from Descrybe.ai. For citation checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.

Norma Kay Hubbard, Individually, and on Behalf of All Similarly Situated v. United Airlines, Inc., a Delaware Corporation, the Pacific Ins. Co., Ltd., a Hawaii Corp., Hartford Life & Accident Company, Inc., a Connecticut Corporation

Citations: 927 F.2d 1094; 91 Cal. Daily Op. Serv. 1725; 91 Daily Journal DAR 2773; 136 L.R.R.M. (BNA) 2750; 1991 U.S. App. LEXIS 3573Docket: 90-15187

Court: Court of Appeals for the Ninth Circuit; March 7, 1991; Federal Appellate Court

Narrative Opinion Summary

This case involves an appeal by Norma Kay Hubbard, who challenged the dismissal of her RICO action against United Airlines and its claims adjusters. The core issue was whether her allegations of fraud concerning disability benefits under a collective bargaining agreement (CBA) were preempted by the Railway Labor Act (RLA). The district court dismissed her claims, reasoning that they constituted a minor dispute under the RLA, necessitating arbitration as the exclusive remedy. The Ninth Circuit affirmed this dismissal, conducting a de novo review and referencing relevant Supreme Court and circuit precedents. The court concluded that RICO does not provide substantive guarantees to workers that would preclude RLA preemption. Hubbard's argument, referencing a recent Supreme Court interpretation of Section 301(a) of the LMRA, was dismissed as RLA preemption is more comprehensive. The court underscored that her RICO claims stemmed directly from obligations established by the CBA. Consequently, the court upheld that arbitration is the appropriate channel for resolving such disputes, reaffirming the RLA’s preemptive scope over contractual disputes grounded in CBAs.

Legal Issues Addressed

Distinction between RLA and LMRA Preemption

Application: The court noted that RLA preemption is broader than LMRA preemption, impacting Hubbard's arguments against preemption.

Reasoning: The court determines that preemption under the Railway Labor Act (RLA) is broader than under Section 301, as established in Grote v. Trans World Airlines.

Interpretation of Collective Bargaining Agreements

Application: The court emphasized that minor disputes requiring CBA interpretation are subject to arbitration under the RLA.

Reasoning: Minor disputes, which arise from existing agreements, can be resolved through the interpretation of those agreements, as highlighted in Regional Airline Pilots Ass'n v. Wings West Airlines.

Jurisdiction over Minor Disputes

Application: The RLA grants exclusive jurisdiction over minor disputes to an adjustment board, precluding federal court intervention.

Reasoning: The RLA grants exclusive jurisdiction over minor disputes to an adjustment board.

Preemption under the Railway Labor Act (RLA)

Application: The court held that Hubbard's RICO claims were preempted by the RLA as they arose from obligations under the collective bargaining agreement.

Reasoning: The district court ruled that her claims were preempted by the Railway Labor Act (RLA), categorizing them as a minor dispute related to the obligations outlined in the CBA.

RICO Claims and CBA Obligations

Application: Hubbard's RICO claims were dismissed because they were based on rights established by the CBA, making arbitration the exclusive remedy.

Reasoning: Despite alleging deliberate underpayments, her claims are based on violations of rights established by the collective bargaining agreement (CBA), making arbitration before the System Board of Adjustment her exclusive remedy.