Burlington Northern & Santa Fe Railway Co. v. Collins
Burlington Northern & Santa Fe Railway Co. v. Collins
Opinion of the Court
After sustaining on-the-job injuries while working for Burlington Northern and Santa Fe Railway Company, William E. Collins and Seawood Johnson filed Federal Employers’ Liability Act claims and applications for temporary restraining orders; Collins filed on October 29, 1998, and Johnson filed on November 5, 1998. Collins and Johnson sought TROs to enjoin Burlington Northern from holding an investigative hearing concerning their re
Burlington Northern argues (1) that the trial court had no jurisdiction to enjoin it from exercising its contractual rights and obligations under its collective-bargaining agreements with these plaintiffs; and (2) that the trial court erroneously held that these plaintiffs met the evidentiary requirements for a preliminary injunction. After considering the record and the briefs of the parties, we reverse and remand.
Burlington Northern argues that the plaintiffs’ claims for preliminary injunctions were preempted by the Railway Labor Act. “The RLA ... sets up a mandatory arbitral mechanism to handle disputes ‘growing out of grievances or out of the interpretation or application of agreements concerning rates of pay, rules, or working conditions,’ 45 U.S.C. § 153 First (i).” Hawaiian Airlines, Inc. v. Norris, 512 U.S. 246, 248, 114 S.Ct. 2239, 129 L.Ed.2d 203 (1994). The RLA applies to two kinds of controversies: “major disputes,” which “relate to ‘ “the formation of [collective-bargaining] agreements or efforts to secure them” ’ and “minor disputes,” which involve “the interpretation or application of [collective-bargaining] agreements covering rates of pay, rules, or working conditions.” Id., 512 U.S. at 252-53, 114 S.Ct. 2239. See Consolidated Rail Corp. v. Railway Labor Executives’ Ass’n, 491 U.S. 299, 109 S.Ct. 2477, 105 L.Ed.2d 250 (1989). Burlington Northern argues that the circuit court lacked jurisdiction to entertain the preliminary-injunction requests because, it says, those requests constituted a “minor dispute” and were preempted by the RLA. The plaintiffs argue that this dispute is neither a “major dispute” nor a “minor dispute.” They argue that the investigation hearing deprives them of the opportunity to proceed with their FELA claims with the procedural protections afforded by the Alabama Rules of Civil Procedure because (1) the investigation hearing allows Burlington Northern to interrogate them outside the judicial process and to address issues that would be subject to discovery under the Alabama Rules of Civil Procedure; and (2) the investigation hearing deprives them of their right to counsel. We disagree. We conclude that the plaintiffs’ requests for a preliminary injunction constituted a “minor dispute” because they related to the application of the collective-bargaining agreements.
Burlington Northern sought in both cases to enforce those provisions in the collective-bargaining agreements that allowed it to conduct investigation hearings. The collective-bargaining agreement between Burlington Northern and the United Transportation Union, and the collective-bargaining agreement between Burlington Northern and the Brotherhood of Locomotive Engineers, both provide that employees cannot be disciplined without a hearing. In each collective-bargaining agreement, Burlington Northern and the union (one union acting on behalf of Collins and the other acting on
REVERSED AND REMANDED.
. In Boncouri, the court held that it lacked jurisdiction not because the FELA claim was preempted, but because the action had been filed in a state court and could not be removed to the federal court.
Reference
- Full Case Name
- Burlington Northern and Santa Fe Railway Company, Inc. v. William E. Collins. Burlington Northern and Santa Fe Railway Company, Inc. v. Seawood Johnson.
- Cited By
- 1 case
- Status
- Published