Oka v. United Airlines, Inc.

CourtDistrict Court, N.D. Illinois
DecidedFebruary 23, 2025
Docket1:23-cv-15793
StatusUnknown

This text of Oka v. United Airlines, Inc. (Oka v. United Airlines, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Oka v. United Airlines, Inc., (N.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

JOSEPH JOHN OKA, ) ) Plaintiff, ) ) vs. ) Case No. 23 C 15793 ) AIR LINE PILOTS ASSOCIATION, ) INTERNATIONAL, et al., ) ) Defendants. )

MEMORANDUM OPINION AND ORDER

MATTHEW F. KENNELLY, District Judge:

Joseph Oka is a pilot employed by United Airlines, Inc. He has sued United and his union, the Air Line Pilots Association International (ALPA), for violations of Title VII of the Civil Rights Act of 1964, and, with respect to ALPA, for breach of its duty to fairly represent him. Oka's claims largely arise from a requirement instituted by United in August 2021 requiring its employees to be vaccinated against COVID-19 unless granted a medical or religious accommodation. Oka made a request for a religious accommodation in late August 2021. United granted the request, but the accommodation amounted to unpaid leave with no benefits. Oka contends that employees who were given medical accommodations were unpaid but kept their benefits and that this amounted to disparate treatment based on his religion. In a previous ruling, the Court dismissed some of Oka's claims against United but allowed him to proceed on Title VII claims against United for religious-based discrimination and failure to accommodate his religious beliefs. Oka also sued ALPA under Title VII and for breach of its duty of fair representation (DFR). The Court dismissed Oka's DFR claims against ALPA except for a claim arising from its handling of a grievance Oka filed in 2022, which the parties call the "forced downgrade grievance." Specifically, the Court concluded that Oka's

allegations that ALPA's alleged reversal of course on a claimed earlier commitment to pursue the grievance and its alleged stalling of the grievance would support a claim that the union arbitrarily withdrew its support from the grievance in violation of the DFR. Dkt. 59 at 24-25. With regard to Oka's Title VII claims against ALPA, however, the Court concluded that Oka had failed to plausibly allege that any of ALPA's actions regarding United's vaccination policy or his grievances amounted to intentional discrimination based on religion; that ALPA failed to accommodate his religious beliefs; or that ALPA had retaliated against him for taking action protected by Title VII. Id. at 25-29. Oka then filed an amended complaint and a second amended complaint. Oka made some procedural missteps, but the Court will skip over those for present

purposes. ALPA has moved to dismiss the second amended complaint under Rule 12(b)(6) for failure to state a claim and, in part, under Rule 12(b)(1) for lack of standing. The Court will address Oka's Title VII claims first and will then address his DFR claim(s). 1. Title VII claims Oka attempts to assert a Title VII claim of religion-based discrimination against ALPA based on how it dealt with LOA 21-02. LOA 21-02 was a May 2021 letter of agreement between United and the union that barred United from requiring COVID-19 vaccinations, provided financial incentives for getting vaccinated, and allowed United to designate airports as vaccine destinations if those locations limited access by unvaccinated pilots. But in early August 2021, United instituted a vaccination mandate that required employees to submit proof of vaccination for COVID-19 by a date in late September 2021. Oka's claim based on ALPA's involvement in LOA 21-02 is untimely. Title VII

requires, as a prerequisite to suit, timely filing of a charge with the Equal Employment Opportunity Commission and exhaustion of the EEOC administrative process. 42 U.S.C. § 2000e-5(f)(1); Zipes v. Trans World Airlines, Inc., 455 U.S. 385, 393 (1982). An aggrieved person has 300 days from the date of the discriminatory action to file an EEOC charge. 42 U.S.C. § 2000e-5(e)(1). LOA 21-02 was issued in May 2021, but Oka did not file an EEOC charge until about a year later, in May 2022. That was well beyond the 300-day limit. Oka's only excuse for the delay is that LOA 21-02 was in effect until late September 2021. That's not good enough. The limitations period starts when the employment decision is made and communicated to the employees, see, e.g., Stepney v. Naperville Sch. Dist. 203, 392 F.3d 236, 240 (7th Cir. 2004), and in this case

that was in May 2021. Timeliness aside, Oka includes no allegations in his second amended complaint that plausibly support a contention that ALPA's involvement in LOA 21-02 amounted to religious-based discrimination: the LOA included no differential treatment for unvaccinated religious and non-religious objectors. For these reasons, any Title VII claim against ALPA related to LOA 21-02 is dismissed. In his response to the motion to dismiss, Oka describes the remainder of his religious discrimination claim against ALPA as follows (and the Court will hold him to this going forward): First, ALPA engaged in discrimination by acting in concert with UA to offer different and preferable benefits to medically accommodated pilots that were inaccessible to religiously accommodated pilots. Second, ALPA supported grievances pressed by other classes of protected pilots more favorably than claims made by religiously accommodated pilots.

Pl.'s Resp. to Def.'s Mot. to Dismiss at 10. On the second of these points, the Court overrules, as it did before, Oka's contention that it violated Title VII for ALPA to pursue grievances on behalf of terminated employees but not on behalf of those who were put on unpaid leave. The Court previously ruled that "nothing [in the complaint] suggests that ALPA's decision to focus its resources on pilots who had been terminated rather than pilots who had been 'accommodated' (for both religious and medical reasons) was motivated by the religious nature of the pilots' objections." Dkt. 59 at 26-27. The same deficiency exists in the second amended complaint; Oka has not cured it. In his response to the motion to dismiss, Oka says, rather cryptically, that "medically exempt employees were assisted by purposeful and deliberate inaction," Pl.'s Resp. to Def.'s Mot. to Dismiss at 13, but he makes no effort to explain this and, more importantly, there is nothing in the complaint regarding a disparate practice in pursuing grievances for those with medical exemptions vis-à-vis those with religious exemptions. Oka's Title VII claim to this effect is dismissed, this time with prejudice given that he has now had two chances to plead a viable claim but has failed to do so. On the first point argued by Oka in support of his religious discrimination claim, the core of Oka's claim is that "ALPA deliberately looked the other way to secure benefits for the medically exempt, even when those benefits were a violation of multiple company policies and the UPA. For the religious, ALPA did nothing and failed to press their grievances." Id. at 11 (footnote omitted). ALPA says that the law didn’t require it to push United to eliminate benefits for the medically exempt. That misses the point: Oka's contention is that ALPA made no effort to push United to treat religious objectors the same, more favorable way that it treated medical objectors.

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

Related

Zipes v. Trans World Airlines, Inc.
455 U.S. 385 (Supreme Court, 1982)
Sonja Stumo v. United Air Lines, Inc.
382 F.2d 780 (Seventh Circuit, 1967)
Lawrence Stepney v. Naperville School District 203
392 F.3d 236 (Seventh Circuit, 2004)
Brooks v. Air Line Pilots Ass'n, International
630 F. Supp. 2d 52 (District of Columbia, 2009)
United States v. Serpico
20 F. App'x 27 (Second Circuit, 2001)
Rios-O'Donnell v. American Airlines, Inc.
837 F. Supp. 2d 868 (N.D. Illinois, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
Oka v. United Airlines, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/oka-v-united-airlines-inc-ilnd-2025.