International Brotherhood of Teamsters v. North American Airlines

This appeal presents the question whether section 2, First of the Railway Labor Act (RLA), 45 U.S.C. § 152 First, read in conjunction with other provisions of the RLA, imposes a status quo requirement prohibiting carriers from unilaterally altering terms or conditions of employment once negotiations toward an initial collective bargaining agreement have begun, but before the agreement has been completed. Following the Supreme Court’s holding in Williams v. Jacksonville Terminal Co., we hold that it does not. 315 U.S. 386, 402-03 , 62 S.Ct. 659 , 86 L.Ed. 914 (1942). We also hold that the district court acted well within its discretion in denying injunctive relief in this case. See Chicago & N.W. Ry. Co. v. United Transp. Union, 402 U.S. 570, 583 , 91 S.Ct. 1731 , 29 L.Ed.2d 187 (1971); Reg’l Airline Pilot Ass’n v. Wings West Airlines, Inc. (Wings West), 915 F.2d 1399, 1402-03 (9th Cir.1990).

I

North American Airlines (“North American”), a Delaware corporation, is a certi fied air carrier engaged in scheduled and charter passenger service, as well as service for the Department of Defense. See 45 U.S.C. §§ 181-182 . North American employs approximately 600 employees, including 120…