James W. Felt v. Atchison, Topeka & Santa Fe Railway Co.

This case requires us to reconcile the mandatory arbitration mechanism of the Railway Labor Act (“RLA”), 45 U.S.C. §§ 151 et seq., and the statutory protections provided by Title VII of the Civil Rights Act, 42 U.S.C. §§ 2000e et seq. The issue of first impression is whether a Title VII claim of employment discrimination is a “minor dispute” under the RLA and therefore subject to mandatory arbitration.

Plaintiff-appellant James W. Felt brought a Title VII suit against defendant-appellee Atchison, Topeka & Santa Fe Railway Co., alleging that the railroad failed to accommodate his religious preferences and seeking lost pay and benefits as provided for by terms of a collective bargaining agreement (“CBA”). In a published decision, the district court granted the defendant’s motion to dismiss because it ruled Felt’s claim constituted a “minor dispute” within the meaning of the RLA. See Felt v. Atchison, T. & S.F.R. Co., 831 F.Supp. 780, 783-85 (C.D.Cal.1993). Controlling Supreme Court authority teaches that the dispute at issue is not a “minor dispute,” involving as it does rights that exist independently of the CBA, and so we reverse. See Hawaiian Airlines, Inc. v. Norris, — U.S. -,…