Alaska Airlines v. Dep't of Labor & Indus.

CourtWashington Supreme Court
DecidedJune 29, 2023
Docket100,485-1
StatusPublished

This text of Alaska Airlines v. Dep't of Labor & Indus. (Alaska Airlines v. Dep't of Labor & Indus.) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Alaska Airlines v. Dep't of Labor & Indus., (Wash. 2023).

Opinion

NOTICE: SLIP OPINION (not the court’s final written decision)

The opinion that begins on the next page is a slip opinion. Slip opinions are the written opinions that are originally filed by the court. A slip opinion is not necessarily the court’s final written decision. Slip opinions can be changed by subsequent court orders. For example, a court may issue an order making substantive changes to a slip opinion or publishing for precedential purposes a previously “unpublished” opinion. Additionally, nonsubstantive edits (for style, grammar, citation, format, punctuation, etc.) are made before the opinions that have precedential value are published in the official reports of court decisions: the Washington Reports 2d and the Washington Appellate Reports. An opinion in the official reports replaces the slip opinion as the official opinion of the court. The slip opinion that begins on the next page is for a published opinion, and it has since been revised for publication in the printed official reports. The official text of the court’s opinion is found in the advance sheets and the bound volumes of the official reports. Also, an electronic version (intended to mirror the language found in the official reports) of the revised opinion can be found, free of charge, at this website: https://www.lexisnexis.com/clients/wareports. For more information about precedential (published) opinions, nonprecedential (unpublished) opinions, slip opinions, and the official reports, see https://www.courts.wa.gov/opinions and the information that is linked there. For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. FILE THIS OPINION WAS FILED FOR RECORD AT 8 A.M. ON JUNE 29, 2023 IN CLERK’S OFFICE SUPREME COURT, STATE OF WASHINGTON JUNE 29, 2023 ERIN L. LENNON SUPREME COURT CLERK

IN THE SUPREME COURT OF THE STATE OF WASHINGTON

ALASKA AIRLINES, INC., NO. 100485-1 Respondent, EN BANC v. STATE OF WASHINGTON DEPARTMENT OF LABOR AND Filed: June 29, 2023 INDUSTRIES, Appellant.

GORDON MCCLOUD, J.—The Washington family care act (WFCA), RCW

49.12.265-.295, requires employers to allow employees to use earned time off to

care for a sick family member, even if the earned time off is called something other

than “sick leave” or “family care leave.” It is a statutory choice of leave mandate

that trumps conflicting terms of a collective bargaining agreement (CBA) or an

employee policy to the contrary on this specific topic.

But this statute also limits the reach of its choice of leave mandate: “The

employee taking leave under the circumstances described in this section must

comply with the terms of the [CBA] . . . applicable to the leave, except for any For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. No. 100485-1

terms relating to the choice of leave.” RCW 49.12.270(1). And a closely related

statute reiterates that limitation; RCW 49.12.290 states, “Nothing in RCW

49.12.270 through 49.12.295 shall be construed to reduce any provision in a

[CBA].”

In this case, Alaska Airlines’ (AA’s) CBA with its flight attendants requires

those flight attendants to schedule vacation days in advance. The Department of

Labor & Industries (L&I) argues that RCW 49.12.270 displaces the CBA’s

mandatory advance scheduling requirement term without explicitly saying so. AA

argues that it does not.

We agree with AA. It takes more to displace a mandatory CBA term than

RCW 49.12.270 contains. In fact, RCW 49.12.270 explicitly preserves non-

choice-of-leave terms of the CBA and RCW 49.12.290 bars interpreting RCW

49.12.270 to “reduce any provision in a [CBA].” We therefore hold that RCW

49.12.270 does not displace the advance scheduling requirement of the CBA.

We affirm the decision of the superior court.

FACTUAL AND PROCEDURAL HISTORY

I. AA flight attendants’ vacation and sick leave are governed—in detail— by the CBA

AA and the Association of Flight Attendants-Communication Workers of

America, AFL-CIO (AFA) negotiated a CBA that covers AA’s flight attendants.

2 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. No. 100485-1

Clerk’s Papers (CP) at 2138-2232. The CBA details how flight attendants earn sick

and vacation days. Id. at 2213-18, 2176-83.

AA flight attendants earn vacation days based on their past year of service.

Id. at 2176. Flight attendants are “entitled” to their annual allotment starting on

December 31 of every year. Id. During the fall of every year, flight attendants bid

for specific vacation days for the upcoming year. Id. AA accepts bids based on

seniority, and the vacation time gets blocked off in each flight attendant’s yearly

schedule. Id.

Flight attendants can cash out their vacation days for pay up to seven days in

advance of the vacation period. Id. “Cashing out” means that flight attendants

choose to receive vacation pay earlier than the pay period of the scheduled time

off, but the vacation days remain on their schedule. Id. at 2176, 1651. Flight

attendants can also trade vacation days with other flight attendants, but AA must

approve the trade by the first day of the month preceding the month in which the

scheduled vacation falls. Id. at 2176, 2170. The CBA provides that flight

attendants can use their allotted vacation days for other types of leave—medical

leaves of absence, maternity leaves of absence, and bereavement leaves. Id. at

2177-79.

Flight attendants also accrue and are entitled to sick leave. A flight attendant

accrues one “trip for pay” (TFP) of paid sick leave for every ten TFPs flown. Id. at

3 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. No. 100485-1

2181. A TFP is based on mileage flown, not days or hours worked, and a flight

attendant can bank a total of 1,443 TFPs. Id. at 2143, 2181. A flight attendant must

call in sick at least three hours before the flight’s scheduled departure to avoid

receiving a disciplinary point. Id. at 2213-14.

AA uses an attendance control program that assigns disciplinary points for

every unplanned absence. Id. at 2213-14. The number of points assessed bears an

inverse relationship to the amount of notice provided—the more notice provided,

the fewer points assessed. Id. If a flight attendant reports an “emergency drop,”

which occurs when an attendant calls in absent for a nonqualifying emergency,

then that employee accumulates half of a disciplinary point. Id. at 2214, 2218. A

flight attendant can accumulate 4.5 points without disciplinary action. Id. at 2214.

A flight attendant who receives 9.5 disciplinary points becomes eligible for

possible termination. Id. A flight attendant who receives 12 disciplinary points is

terminated from employment. Id. However, a flight attendant can work off

disciplinary points—for every calendar quarter that the flight attendant works

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