Wood v. International Brotherhood of Teamsters

CourtDistrict Court, D. Alaska
DecidedJanuary 14, 2025
Docket3:24-cv-00053
StatusUnknown

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

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Wood v. International Brotherhood of Teamsters, (D. Alaska 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ALASKA

JEREMY WOOD, Plaintiff, v. INTERNATIONAL BROTHERHOOD Case No. 3:24-cv-00053-SLG OF TEAMSTERS, et al., Defendants. ORDER ON MOTIONS TO DISMISS

Before the Court are two motions to dismiss. At Docket 25 is a Motion to Dismiss filed by the International Brotherhood of Teamsters (“IBT”) and Teamsters Local Union 769 (“Local 769”) (collectively, the “Unions”), and at Docket 26 is a Motion to Dismiss filed by Northern Air Cargo (“NAC”). Plaintiff Jeremy Wood responded in opposition at Docket 29, to which the Unions replied

at Docket 37 and NAC replied at Docket 38. Oral argument was not requested by any party and was not necessary to the Court’s determination. For the reasons set forth below, both motions are DENIED. BACKGROUND NAC is a commercial air carrier and corporation headquartered in

Anchorage, Alaska and subject to the provisions of the Railway Labor Act, 45 U.S.C. §§ 151 et seq. (“RLA”).1 “IBT is the certified bargaining representative for the NAC pilots and a ‘representative’ labor union subject to the provisions of the RLA.”2 “Local 769 represents South Florida Teamsters including NAC pilots from

Orlando to Key West” and is a “representative” within the meaning of the National Labor Relations Act.3 Mr. Wood is a commercial air pilot who was hired by NAC as a First Officer in September 2018.4 He is an “employee” covered by the RLA.5 After NAC

terminated Mr. Wood’s employment in May 2020, Mr. Wood and IBT filed two grievances. NAC responded by reinstating Mr. Wood pursuant to a settlement agreement in October 2021.6 On April 25, 2022, NAC notified Mr. Wood of the termination of his employment due to “observed performance deficiencies and a failure to qualify in [his] recent . . . First Officer training effort.”7 On May 6, 2022, Mr. Wood and IBT

filed a grievance alleging that this second termination was without just cause.8 As part of Local 769’s investigation, it sent a letter to NAC on June 1, 2022 requesting

1 Docket 1 at ¶¶ 10, 11 (citing 45 U.S.C. §§ 151 First, 181); see also Docket 26 at 2. 2 Docket 1 at ¶ 7 (citing 45 U.S.C. §§ 151 Sixth, 181); see also Docket 26 at 2–3. 3 Docket 1 at ¶ 9 (citing 29 U.S.C. §152(5), (4)); see also Docket 26 at 3. 4 Docket 1 at ¶¶ 4, 12; see also Docket 25 at 3; Docket 26 at 3–4. 5 Docket 1 at ¶ 5 (citing 45 U.S.C. § 151 Fifth); see also Docket 26 at 3. 6 Docket 1 at ¶ 12; see also Docket 26 at 4. 7 Docket 25-6 at 2. 8 Docket 1 at ¶ 14. information about Mr. Wood’s employment and alleged infractions.9 On September 19, 2023, Local 769 sent a proposed settlement agreement to Mr.

Wood, and advised him that the agreement—which included a payment of $25,000 and a release of all claims against NAC—was “a most favorable resolution of an unwinnable case.”10 Local 769 advised Mr. Wood that its investigation had produced “very detailed and specific reasons to support the conclusion that a failure to qualify occurred,” and therefore, it was unwilling to pursue arbitration on his behalf.11

On March 6, 2024, Mr. Wood initiated this action. His Complaint seeks an order compelling arbitration before an impartial System Board of Adjustment.12 The Complaint alleges that airline employees have an individual statutory right under the RLA to access arbitration, with or without the union as a party.13 It appears undisputed that Mr. Wood does not have the authority to compel

arbitration under the terms of the Collective Bargaining Agreement (“CBA”) between NAC and IBT.14 The CBA recognizes IBT “as the duly designated and authorized representative” of NAC’s pilots for the purposes of the RLA, and it

9 Docket 25-8 at 2–3. 10 Docket 25-10 at 2; see also Docket 25-9 at 2–3. 11 Docket 25-10 at 2. 12 Docket 1 at 8. 13 Docket 1 at ¶ 18. 14 See generally Docket 1; Docket 29. establishes a System Board of Adjustment to decide disputes “when such disputes have been properly submitted to The Board by the Union.”15

The Unions and NAC each filed a motion to dismiss.16 Both sets of defendants assert that Mr. Wood does not have an individual statutory right under the RLA to compel arbitration, and thus the Complaint fails to state a valid claim for relief.17 NAC asserts further that even if Mr. Wood did have an individual statutory right to compel arbitration, there is no private cause of action for him to enforce it.18

The instant motions concern differing interpretations of the RLA. The RLA was “originally passed to regulate conduct in the railroad industry.”19 It is aimed at providing “for the prompt and orderly settlement of all disputes growing out of grievances or out of the interpretation or application of agreements covering rates of pay, rules, or working conditions.”20 45 U.S.C. § 153 First establishes the

National Railroad Adjustment Board (“NRAB”) to handle “minor disputes” in the railroad industry, or “grievances . . . which inevitably appear in the carrying out of major agreements and policies[,] or arise incidentally in the course of an

15 Docket 26-1 at 4, 209 (emphasis added). 16 Docket 25; Docket 26. 17 Docket 25 at 7; Docket 26 at 2. 18 Docket 26 at 2. 19 Capraro v. United Parcel Serv. Co., 993 F.2d 328, 331 n.4 (3d Cir. 1993). 20 45 U.S.C. § 151a(5). employment.”21 In 1936, the RLA was amended to include the airline industry,22 and all of the provisions of the RLA except for § 153 and the NRAB were extended to cover air carriers.23 Instead, 45 U.S.C. § 184 directs air carriers and unions to

establish their own boards of adjustment to arbitrate these “minor disputes.”24 Section 184 is the section that is at issue in this case. The Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331. LEGAL STANDARD

A party may seek dismissal under Federal Rule of Civil Procedure 12(b)(6) for a complaint’s “failure to state a claim upon which relief can be granted.” “To survive a motion to dismiss [under Rule 12(b)(6)], a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’”25 “A complaint may fail to show a right to relief either by lacking a cognizable legal theory or by lacking sufficient facts alleged under a cognizable

legal theory.”26 In deciding a motion to dismiss under Rule 12(b)(6), “all material

21 Int'l Ass'n of Machinists v. Street, 367 U.S. 740, 760 (1961); Elgin, J. & E. Ry. Co. v. Burley, 325 U.S. 711, 724 (1945), adhered to on reh'g, 327 U.S. 661 (1946).

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