Alaska Airlines, Inc. v. Judy Schurke, et al.

In order to promote stability in labor-management relations and minimize disruptions in vital transportation services, the Railway Labor Act (RLA) requires mandatory arbitration for all disputes in the railroad and airline industries that require the “interpretation or application” of a collective bargaining agreement (CBA). 45 U.S.C. §§ 153(i), 184. State law claims that involve the interpretation or application of a CBA are therefore preempted. This Court applies the same preemption analysis under the RLA as it does under Section 301 of the Labor Management Relations Act (LMRA), which governs all “[s]uits for violation of contracts between an employer and a labor organization representing employees.” 29 U.S.C. § 185(a); see Hawaiian Airlines, Inc. v. Norris, 512 U.S. 246, 260 (1994) (observing that the RLA and LMRA preemption standards are “virtually identical”). This case arises from a dispute between an airline and a flight attendant over the latter’s claim that she was entitled to reschedule claimed vacation time to cover for an upcoming flight. Although the applicable CBA governs the taking and rescheduling of such vacation, the plaintiff sought to avoid arbitration by pleading her claim solely in terms of the violation of state law. Splitting 6-5, an en banc panel of the Ninth Circuit held—in direct conflict with the decisions of other courts of appeals—that federal courts cannot inquire into the nature and scope of the state law claim in conducting this preemption inquiry. App. 38a-39a. According to the majority, a plaintiff’s mere allegation that her claim turns on state law, not a CBA, is thus alone sufficient to avoid the RLA’s