Air Transport Association of America, Inc. d/b/a Airlines for America v. Nicole Blissenbach in her official capacity as Commissioner of the Department of Labor and Industry

District Court, D. Minnesota·Decided April 10, 2026·No. 0:24-cv-04657·Unknown

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

Air Transport Association of America, Case No. 24-cv-04657 (JWB/ECW) Inc. d/b/a Airlines for America,

Plaintiff,

v. ORDER

Nicole Blissenbach in her official capacity as Commissioner of the Department of Labor and Industry,

Defendant.

This case is before the Court on Plaintiff Air Transport Association of America, Inc. d/b/a Airlines for America’s (“A4A”) Motion to Compel the Air Line Pilots Association, International’s (“ALPA”) production of documents (Dkt. 77) (“the Motion”). For the reasons set forth below, the Court denies the Motion and, pursuant to Federal Rule of Civil Procedure 37(a)(5)(B), grants the protective order sought by APLA in response to the Motion. I. BACKGROUND A4A is a nonprofit corporation that advocates on behalf of ten federally regulated air carriers: Alaska Airlines, Inc., American Airlines, Inc., Delta Air Lines, Inc., Hawaiian Airlines, Inc., JetBlue Airways Corp., Southwest Airlines Co., United Airlines, Inc., Atlas Air, Inc., FedEx Express, and UPS Airlines. (Dkt. 1 at 5.)1 A4A brought this

1 Unless stated otherwise, references to page numbers in this Order are to the CM/ECF pagination. action against Nicole Blissenbach in her official capacity as Commissioner of the Minnesota Department of Labor and Industry (“the Commissioner”). (Id. at 6.) A4A

brought this action to challenge the application of the Minnesota Earned Sick and Safe Time Law, Minn. Stat. § 181.9445 et seq. (“the Minnesota law”), to A4A’s member airlines. (Id. at 1.) The Minnesota law sets a minimum amount of sick and safe time that employees must accrue, and governs how that time may be used. See Minn. Stat. § 181.9445 et seq. A4A argues that, as applied to its member airlines, the Minnesota law is preempted by the Airline Deregulation Act of 1978, 49 U.S.C. § 41701 et seq. (the

“ADA”), and the Railway Labor Act, 45 U.S.C. § 151 et seq. (the “RLA”). (Dkt. 1 at 1- 2.) On January 21, 2025, the Commissioner filed a motion to dismiss for failure to state a claim upon which relief can be granted. (Dkt. 21 at 1.) On May 14, 2025, United States District Judge Jerry W. Blackwell held a hearing on the Motion. (Dkt. 52.) Judge

Blackwell denied the motion on the record. (Dkt. 55 at 32:20-24.)2 Judge Blackwell explained that: The plaintiff alleges that the Minnesota law intrudes upon the collective bargaining process by regulating employment terms already subject to negotiation and by applying to leave benefits beyond the statutory minimum. So at this stage, those allegations are sufficient to proceed to discovery. And as I have emphasized, the proof ought to be in the pudding here. I mean, I will hear the arguments about what is likely to occur in the future based upon the statutes or policies, but I want to see kind of what the data shows already. And there may be grounds to have a very good argument that past ought to be prologue. That if it hasn’t happened, then there has to be an argument for why it should be credible that it’s going to happen if it’s not already in the

2 Transcripts are cited in page:line format. history. Since the history is, in fact, pled as a part of the complaint, then there had to have been a good-faith basis for pleading it. So I’d like to see it. So the case will proceed to discovery, but it won’t be the discovery one-on- one so to speak. The issue presented here is first and foremost one of preemption, and, specifically, whether the Minnesota law creates an impermissible burden on airline operations or disrupts the bargaining process under the RLA. And so discovery will initially be limited to those questions. So let me be clear enough that the discovery that I’ll order won’t be an invitation for party-by-party damages discovery or a broad inquiry into all employment practices; rather, I’m going to permit focused discovery, narrow discovery on, number one, whether the Minnesota law as applied to plaintiff’s member airlines has caused or would likely cause a significant impact on airline services, prices, or routes; and then, two, whether the law imposes operational or administrative burdens inconsistent with uniform federal regulations of airlines; and then, number three, whether it displaces or interferes with collective bargaining under the RLA. (Id. at 34:1-35:12 (emphasis added).) Judge Blackwell further clarified that: I’m anticipating that the plaintiff’s permitted discovery would include things such as discovery limited to the operational impact on the airlines; you know, regulatory and compliance burdens, that is, documents showing the admin costs and burdens associated with tracking compliance under the Minnesota law as compared to other jurisdictions; FAA crew staffing requirements and safety compliance. A fourth area, the comparative analysis of state and federal regulation might be helpful to see. An example of that would be evidence on how the Minnesota law interacts with, modifies, or contradicts federally governed airline labor relations under the RLA. So I would be -- there may be something there that could be instructive on the issues before the Court. (Id. at 36:1-15 (emphasis added).) The case proceeded to discovery, and on August 5, 2025, A4A served a subpoena on nonparty ALPA. (Dkt. 79-4.) The subpoena included eight requests for production. (Id.) The eighth request is reproduced below: All DOCUMENTS and COMMUNICATIONS CONCERNING any proposals, notes, drafts, discussions, or other documents presented in collective bargaining negotiations between Delta Air Lines, Inc., including any PERSONS purporting to or acting on its behalf, and ALPA, including any PERSONS purporting to or acting on its behalf, relating to SICK LEAVE, time off, attendance, reliability, or availability of AIRLINE employees and any DOCUMENTS or COMMUNICATIONS memorializing, referencing, or in any way concerning such DOCUMENTS or COMMUNICATIONS, from the time negotiations began for the collective bargaining agreement immediately preceding the operative collective bargaining agreement through present.[3] (Id. at 13.) ALPA objected to Request 8 as follows: ALPA objects to this request because it is overly broad and unduly burdensome. ALPA also objects to the extent that it seeks documents protected by attorney-client privilege, attorney work-product privilege, and common-interest privilege. ALPA further objects to this request because inasmuch as it calls for documents shared with Delta Airlines, Inc. (“Delta”), a constituent Airline and member of Plaintiff, it calls for information readily available to Plaintiff from Delta, which is more convenient and less burdensome than seeking these documents from ALPA (See Subpoena Definitions 3, 17; Subpoena Ex. 1, Compl. ¶ 7). ALPA also objects to this request as unduly burdensome to the extent that it seeks internal bargaining strategies not shared with Delta, which are subject to the labor-relations privilege, the production of which would cause irreparable injury to ALPA and outweigh any potential benefit to Plaintiff. Moreover, such an overly broad and unduly burdensome request is not proportional to the needs of the case in resolving whether the Law interferes with or displaces collective bargaining under the RLA, which is a process that involves the presentation and discussion of proposals between the respective parties. Accordingly, ALPA will not produce any documents in response to this request. (Dkt. 79-5 at 6.) A4A subsequently clarified that any responsive documents already within Delta’s possession, such as collective bargaining proposals exchanged between

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Air Transport Association of America, Inc. d/b/a Airlines for America v. Nicole Blissenbach in her official capacity as Commissioner of the Department of Labor and Industry, (mnd 2026).

Air Transport Association of America, Inc. d/b/a Airlines for America v. Nicole Blissenbach in her official capacity as Commissioner of the Department of Labor and Industry (Air Transport Association of America, Inc. d/b/a Airlines for America v. Nicole Blissenbach in her official capacity as Commissioner of the Department of Labor and Industry) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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