International Brotherhood of Teamsters, Airlines Division v. Allegiant Air, LLC

I. INTRODUCTION

Allegiant Air is an airline operating from Las Vegas, Nevada. In 2004, Allegiant’s employees organized a pilot advocacy group (the Allegiant Air Pilots Advocacy Group, or “AAPAG”) and elected representatives to bargain with the airline on their behalf. Over the next few years, AAPAG and Allegiant negotiated and agreed to several different Pilot Work Rules, detailed documents that outlined Al-legiant’s policies and work conditions. In 2012, some pilots decided they wanted to unionize. TheJTeamsters expressed interest in representing the pilots and petitioned the National Mediation Board (the Board) to certify them as the pilots’ bargaining representative under the Railway Labor Act (RLA). The Board conducted a secret ballot of the pilots and then certified the Teamsters as the pilots’ RLA representative. Shortly thereafter, Allegiant changed several policies contained in the Work Rules without consulting the Teamsters.

The Teamsters brought suit. They sought a preliminary injunction that would prevent Allegiant from making any policy changes to the Pilot Work Rules while they negotiated a new contract. The Teamsters contend the AAPAG, its predecessor…