International Association of MacHinists and Aerospace Workers, Afl-Cio v. Aloha Airlines, Inc.

The International Association of Machinists and Aerospace Workers (hereinafter IAM) appeals from the district court's order granting summary judgment in favor of Aloha Airlines, Inc. (hereinafter Aloha), on the IAM’s complaint for declaratory relief and damages for breach of the collective bargaining agreement and for violations of the “status quo” provisions of the Railway Labor Act (RLA), 45 U.S.C. §§ 151-188 (1982). This case presents a question of first impression in this circuit: what statute of limitations is applicable to an action for breach of a collective bargaining agreement and for violations of the “status quo” provisions of the RLA? We conclude that principles of res judicata bar relitigation in this action of IAM’s request for compulsory arbitration. However, IAM’s requests for declaratory relief and damages for breach of the collective bargaining agreement and for breach of the RLA’s status quo provisions are not barred as they have not been litigated previously. We further find that the instant action was timely filed within the limitations period then applicable.

I. PERTINENT FACTS AND PROCEDURAL HISTORY

Aloha, a common carrier under section 201 of the RLA, 45…