Flight Options, LLC v. Int'l Bhd. of Teamsters
Flight Options, LLC v. Int'l Bhd. of Teamsters
Opinion of the Court
Flight Options, LLC seeks to vacate an arbitration award that reinstated discharged pilot Captain John Hodges. International Brotherhood of Teamsters (IBT) Airline Division and Teamsters Local Union No. 1108 (Local 1108) move to dismiss the complaint or to transfer venue to the Northern District of Ohio, where both Flight Options and Local 1108 are located. Flight Options, as Plaintiff, has selected the District of Columbia as its preferred forum; Defendant IBT Airline Division, the certified bargaining representative and signatory to the parties' collective bargaining agreement, is located in D.C. All parties agreed to arbitrate Captain Hodges' discharge in the District; the arbitration that is the focus of this case began and continued for two days in D.C.; and Defendant Local 1108 thereby had substantial contacts with D.C. and can be deemed to have consented to jurisdiction in D.C. The Court will deny the motion.
I. FACTS
According to the papers, Flight Options is a luxury jet fractional air carrier headquartered in Richmond Heights, Ohio. Flight Options is signatory to a collective bargaining agreement with IBT Airline Division that covers its pilots. IBT and IBT Airline Division are located in the District of Columbia. Local 1108, which "implement[s]" the collective bargaining agreement, see Defendants' Mot. to Dismiss or Transfer Venue (Defs.' Mot.) [Dkt. 5] at 2, is located in Richmond Heights, Ohio. The contract is governed by the Railway Labor Act (RLA),
"International Brotherhood of Teamsters, Airline Division, ('IBT ALD") [sic] is the National Mediation Board certified representative of the craft or class of pilots at Flight Options for labor law purposes under the RLA."
Flight Options filed its Petition to Vacate Arbitration Award in this Court on September 12, 2017. [Dkt. 1]. On that same date, Local 1108 and IBT Airline Division filed an Action to Enforce Arbitration Award in the District Court of the Northern District of Ohio, where the parties are already conducting other, unrelated, litigation.
II. ANALYSIS
The parties argue over whether this Court in the District of Columbia has jurisdiction over Local 1108, which is an unincorporated association headquartered in Richmond, Ohio, where Flight Options is also headquartered. Specifically, each side cites
(b) Venue in general .-A civil action may be brought in-
(1) a judicial district in which any defendant resides, if all defendants are residents of the State in which the district is located;
(2) a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred ...; or
(3) if there is no district in which an action may otherwise be brought as provided in this section, any judicial district in which any defendant is subject to the court's personal jurisdiction with respect to such action.
(c) Residency .-For all venue purposes-
... (2) an entity with the capacity to sue and be sued in its common name under applicable law, whether or not incorporated, shall be deemed to reside, if a defendant, in any judicial district in which such defendant is subject to the court's personal jurisdiction with respect to the civil action in question ....
Plaintiff Flight Options responds that "[t]here is no dispute that this Court has specific personal jurisdiction over Local 1108" because Local 1108 "purposely availed itself of the privileges of conducting business in this District by actively participating in the arbitration in this District."
*321Plaintiff's Resp. to Def.'s Mot. to Dismiss or Transfer Venue (Pl.'s Resp.) [Dkt. 10] at 2. Plaintiff thereby contends that Local 1108 is a resident of this district under § 1391(b)(1) and that a substantial part of the events giving rise to this suit took place here, providing jurisdiction under § 1391(b)(2). Plaintiff emphasizes that " § 1391(b) [ (2) ] only requires that a substantial part of the events giving rise to" a lawsuit occurred in this forum, not the totality of events or even a majority of them. Pl.'s Resp. at 3.
Both parties cite Burger King Corp. v. Rudzewicz ,
This Court first notes that IBT Airline Division is the certified bargaining agent of the Flight Options pilots, not Local 1108. As is the IBT, this "administrative" arm of IBT is located in the District of Columbia. See Pl.'s Resp. at 2. The underlying legal relationship that binds the parties to arbitrate Captain Hodges' discharge is, therefore, between Flight Options and IBT Airline Division. Local 1108 is the local agent authorized to carry out IBT Airline Division's contractual responsibilities and assert its contractual rights, as Local 1108 has done here.
Local 1108 is headquartered in Richmond, Ohio where it is an unincorporated "resident" that can sue and be sued. However, it also "resides" for purposes of § 1391(c)(2)"in any judicial district in which such defendant is subject to the court's personal jurisdiction with respect to the civil action in question." 28 U.S.C § 1391(c)(2). The question, therefore, returns to § 1391(b) and whether Local 1108 has purposefully established minimum contacts in the District of Columbia through (i) its agreement to arbitrate the Hodges grievance in this district (the location of IBT Airline Division and near the arbitrator in Columbia, MD); and (ii) its active presence in the District of Columbia for the first two days of that arbitration, which is the subject of the instant petition. This is a close question on which the instant record does not provide sufficient historical detail to decide.
However, it is much more clear that the District of Columbia is "a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred."
This conclusion does not deny that other venues, such as the Northern District of Ohio, might also be available. It merely reflects that, not unusually, a lawsuit *322might properly be filed in more than one district court.
III. CONCLUSION
The Motion to Dismiss or Transfer [Dkt. 5] will be denied. A memorializing Order accompanies this Memorandum Opinion.
See Int'l Ass'n of Machinists, AFL-CIO, v. Central Airlines, Inc. ,
Reference
- Full Case Name
- FLIGHT OPTIONS, LLC v. INTERNATIONAL BROTHERHOOD OF TEAMSTERS, AIRLINE DIVISION
- Status
- Published