Term: 2009
Docket: 08-604
Union Pacific Railroad Company v. Brotherhood Of Locomotive Engineers And Trainmen General Committee Of Adjustment, Central Region
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08-604 UNION PACIFIC RAILROAD V. BROTHERHOOD OF LOCOMOTIVE ENGINEERS DECISION BELOW: 537 F.3d 789 CERT. GRANTED 2/23/2009 QUESTION PRESENTED: The Railway Labor Act ("RLA"), 45 U.S.C. §§151 et seq., sets forth a comprehensive framework to resolve labor disputes in the railroad industry through binding arbitration before the National Railroad Adjustment Board ("the Board"). The statute provides that the Board's judgment "shall be conclusive ... except ... for": (1)"failure ... to comply" with the Act, (2) "failure . . . to conform or confine" its order "to matters within . . . the [Board's] jurisdiction," and (3) "fraud or corruption" by a Board member. 45 U.S.C. §153 First (q). This case involves the Board's denial of employee grievance claims for failure to comply with its rules governing proof that the dispute had been submitted to a "conference" between the parties. 45 U.S.C. §152 Second. The Seventh Circuit held that the award must be set aside because the Board violated due process through retroactive recognition of a supposedly "new rule." The questions presented are: 1. Whether the Seventh Circuit erroneously held, in square conflict with decisions of the Third, Sixth, Tenth, and Eleventh Circuits, that the RLA includes a fourth, implied exception that authorizes courts to set aside final arbitration awards for alleged violations of due process. 2. Whether the Seventh Circuit erroneously held that the Board adopted a "new," retroactive interpretation of the standards governing its proceedings in violation of due process. LOWER COURT CASE NUMBER: 06-2542
In the 2009 case Union Pacific Railroad Company v. Brotherhood of Locomotive Engineers and Trainmen General Committee of Adjustment, Central Region, the U.S Supreme Court ruled in favor of Union Pacific Railroad Company. The dispute arose when the railroad company refused to negotiate with a union over claims that were previously dismissed by an arbitration board due to negligence on part of the union's failure to act within time limits set by their collective bargaining agreement. The court held that under Railway Labor Act (RLA), minor disputes must be resolved through binding arbitration before an adjustment board and cannot be reopened for negotiation unless both parties agree or if there is a procedural flaw in original proceedings. In this case, since neither condition was met, it was decided that Union Pacific had no obligation to arbitrate again.
In the dissenting opinion for Union Pacific Railroad Company v. Brotherhood of Locomotive Engineers and Trainmen General Committee of Adjustment, Central Region, Justice Souter argued that the majority misinterpreted the Railway Labor Act (RLA). He believed that it does not require a minor dispute to be arbitrated before being brought to court. Instead, he suggested that if an employer's claim is frivolous or obviously insubstantial then it should not have to go through arbitration first. The RLA was designed to encourage collective bargaining and avoid strikes in order for disputes between employers and employees in the railway industry can be resolved quickly without disrupting transportation services. However, forcing all claims into arbitration could potentially delay resolution as well as discourage parties from pursuing valid claims due to costliness and time-consuming nature of this process.
