Allegiant Air, LLC v. International Brotherhood of Teamsters, Airline Division

CourtDistrict Court, D. Nevada
DecidedMarch 10, 2022
Docket2:20-cv-01866
StatusUnknown

This text of Allegiant Air, LLC v. International Brotherhood of Teamsters, Airline Division (Allegiant Air, LLC v. International Brotherhood of Teamsters, Airline Division) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Allegiant Air, LLC v. International Brotherhood of Teamsters, Airline Division, (D. Nev. 2022).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 ALLEGIANT AIR, LLC, Case No.: 22::2210--ccvv--0011886666--AAPPGG--DDJJAA

4 Plaintiff Order Denying Plaintiff’s Motion for Summary Judgment, Denying Plaintiff’s 5 v. Motion to Dismiss Counterclaim, and Granting Defendants’ Motion to Enforce 6 INTERNATIONAL BROTHERHOOD OF Arbitration Award TEAMSTERS, AIRLINE DIVISION, and 7 AIRLINE PROFESSIONALS [ECF Nos. 21, 22, 25] ASSOCIATION TEAMSTERS LOCAL 8 UNION NO. 2118,

9 Defendants INTERNATIONAL BROTHERHOOD OF 10 TEAMSTERS, AIRLINE DIVISION, and AIRLINE PROFESSIONALS 11 ASSOCIATION TEAMSTERS LOCAL UNION NO. 2118, 12 Counterclaimants, 13 v. 14 ALLEGIANT AIR, LLC, 15 Counterdefendant. 16

17 Defendants International Brotherhood of Teamsters, Airline Division, and Airline 18 Professionals Associate Teamsters Local Union No. 2118 (together, the Union) represent the 19 pilots employed by plaintiff Allegiant Air, LLC. The parties participated in an arbitration before 20 a System Board of Adjustment (SBA) regarding a dispute over Allegiant’s pilot scheduling 21 processes. The SBA granted an award (the Award) in favor of the Union. Allegiant sued to 22 vacate the Award and the Union countersued to enforce it. Allegiant now moves for summary 23 judgment on its claim to vacate the Award and moves to dismiss the Union’s counterclaim, while 1 the Union moves to enforce the Award. Because the SBA did not exceed its jurisdiction and the 2 Award draws its essence from the parties’ collective bargaining agreement (CBA), I deny 3 Allegiant’s motion for summary judgment to vacate the Award, deny Allegiant’s motion to 4 dismiss the Union’s counterclaim, and grant the Union’s motion to enforce the Award.

5 I. BACKGROUND 6 Defendant International Brotherhood of Teamsters, Airline Division represents the pilots 7 employed by Allegiant, an air carrier, for collective bargaining purposes. ECF Nos. 1 at ¶ 3, 4; 8 12 at ¶ 3, 4. Defendant Airline Professionals Association Teamsters Local Union No. 2118 is the 9 local union responsible for day-to-day representation of the pilots. ECF Nos. 1 at ¶ 5; 12 at ¶ 5. 10 In January 2014, Allegiant began using a preferential bidding system (PBS) to create 11 pilots’ schedules.1 ECF No. 21-10 at 12-13. Under the PBS, pilots indicate their preferences for 12 certain activities, such as specific flights, days off, start times, or end times. Id. at 14-15. An 13 algorithm then creates the pilots’ schedules based on the pilots’ indicated preferences, while also 14 abiding by constraints created by regulatory and CBA requirements. Id. at 15-18. The PBS also

15 solves for “must work days” (MWD). A MWD is a day in which the number of assignments 16 which must be filled is greater than or equal to the number of pilots available to fill those 17 assignments. ECF No. 21-6 at 3. Since adopting the PBS (and also following the CBA’s 18 effective date), the PBS solves for MWDs first. Id. at 4. In other words, the PBS first identifies 19 the most senior pilot, meaning the pilot whose preferences have priority over other pilots’ 20

1 The parties previously litigated whether Allegiant’s switch to the PBS during the parties’ CBA 21 negotiations violated its status quo obligations, as well as whether the Union’s threatened strike over Allegiant’s subsequent modifications to PBS violated the Railway Labor Act (RLA). See 22 Int’l Bhd. Of Teamsters, Airline Div. v. Allegiant Air, LLC, No. 2:14–cv–00043–APG–GWF, 2014 WL 3653455 (D. Nev. July 22, 2014), rev’d 788 F.3d 1080 (9th Cir. 2015); Allegiant Air, 23 LLC, v. Int’l Bhd. Of Teamsters, No. 2:15–cv–00580–APG–GWF, 2015 WL 1994779 (D. Nev. May 1, 2015). 1 preferences, then identifies any MWDs, and awards that pilot’s highest work preferences for the 2 MWD before completing the rest of that pilot’s schedule. Id. at 15. The PBS then identifies the 3 next most senior pilot, awards that pilot their highest work preference on any MWD, and then 4 completes the rest of that pilot’s schedule, and so on.2 Id.

5 Allegiant and the Union3 are parties to a CBA governing the pilots’ employment. ECF 6 No. 21-3. Negotiations over the parties’ first CBA began in December 2012 and concluded in 7 June 2016. ECF No. 21-10 at 30. The parties agreed on the CBA’s language regarding 8 scheduling (Id. at 42), but they were unable to agree on certain specifics regarding the PBS. So, 9 they agreed to negotiate a letter of agreement regarding PBS that would specify “software 10 requirements and timeframes for completion of all automation requirements and availability for 11 use” (PBS letter of agreement). ECF No. 21-3 at 95. The parties agreed to negotiate the PBS 12 letter of agreement within 60 days of signing the CBA and to implement it within 180 days of the 13 signing of the CBA. Id. 14 The CBA became effective August 1, 2016. Id. at 2, 160. Its relevant portions are:

15 • Section 1(J) is a management rights provision that reserves for Allegiant the rights to 16 manage its business that Allegiant had prior to entering into the CBA. Id. at 12. 17 • Section 15 governs how Allegiant schedules pilots. Id. at 94-114. The section provides 18 that “[a] [m]onthly [b]id shall be conducted during each” calendar month, and that 19 schedules will “be awarded to current and qualified [p]ilots in order of [s]eniority.” Id. at 20 95. Pilots’ preferences include, among other factors, schedules with a certain number of 21

22 2 Prior to January 2017, Allegiant created schedules slightly differently, but has solved for MWDs first since adopting PBS. Id. at 4, 6-7. 23 3 The Union is the successor union to Local 1224, which is the union listed on the CBA. ECF Nos. 1 at ¶ 5; 12 at ¶ 5. 1 days off, specific days off, and specific trip pairings. Id. at 100. The pilots’ initial 2 schedule awards “shall be accomplished in [s]eniority order by awarding each eligible 3 [p]ilot his . . . preferences in accordance with” the applicable timeline. Id. at 101. Section 4 15(A)(9) also contains the parties’ agreement to negotiate the PBS letter of agreement

5 and the timeline for doing so. Id. at 95. It states that the “agreed upon timeline” for 6 negotiating the letter of agreement “shall be extended if completion of automation is 7 beyond [Allegiant]’s control.” Id. 8 • Section 18 governs the parties’ grievances procedures. Id. at 124-34. Section 18(B) and 9 (C) provide the timeline for grievances and state that prior to filing a grievance, the 10 affected pilot or their Union representative must discuss the dispute with “the System 11 Chief Pilot” within 30 days after the pilot or Union becomes aware of the dispute. Id. at 12 126. The System Chief Pilot must then respond with a decision within 15 days after the 13 discussion. Id. Finally, if the pilot or Union disagrees with the decision, they may file a 14 grievance within 15 days of receiving the decision. Id. at 126-27. Section 18(E) provides

15 that “[t]he time limits contained in . . . Section 18 may be extended by written agreement 16 between the parties” and “all confirmations of mutual extensions of time limits shall be in 17 writing and accomplished as provided in . . . Section 18.” Id. at 129. 18 • Section 19 establishes an SBA to decide disputes arising under the CBA, pursuant to the 19 Railway Labor Act (RLA). Id. at 130. Section 19(A)(2) states that while the SBA has the 20 jurisdiction to decide disputes arising under the CBA, its jurisdiction does not “extend to 21 proposed changes in . . . working conditions and shall have no authority to modify, 22 amend, revise, add to or subtract from any of the terms or conditions of” the CBA. Id.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Elgin, Joliet & Eastern Railway Co. v. Burley
325 U.S. 711 (Supreme Court, 1945)
Elgin, Joliet & Eastern Railway Co. v. Burley
327 U.S. 661 (Supreme Court, 1946)
United Steelworkers v. Enterprise Wheel & Car Corp.
363 U.S. 593 (Supreme Court, 1960)
Union Pacific Railroad v. Sheehan
439 U.S. 89 (Supreme Court, 1979)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Cigna Insurance v. OY Saunatec, Ltd.
241 F.3d 1 (First Circuit, 2001)
United States v. Camilo Juarez-Rodriguez
498 F.2d 7 (Ninth Circuit, 1974)
August Paul Rossi v. Trans World Airlines, Inc.
507 F.2d 404 (Ninth Circuit, 1974)
Deba Edelman v. Western Airlines, Inc.
892 F.2d 839 (Ninth Circuit, 1989)
United States v. Jim Johnson
16 F.3d 166 (Seventh Circuit, 1994)

Cite This Page — Counsel Stack

Bluebook (online)
Allegiant Air, LLC v. International Brotherhood of Teamsters, Airline Division, Counsel Stack Legal Research, https://law.counselstack.com/opinion/allegiant-air-llc-v-international-brotherhood-of-teamsters-airline-nvd-2022.