Brotherhood of Locomotive Eng'rs v. Springfield Terminal Ry. Co.

Brotherhood of Locomotive Engineers, et al. (unions) (plaintiffs) engaged in failed collective bargaining negotiations with Springfield Terminal Railroad Company (Springfield) (defendant) and later entered into mediation, pursuant to the Railway Labor Act (RLA) , 45 U.S.C. § 151-88. The RLA provided that during mediation, the status quo should govern. In other words, a union may not strike and a railroad carrier may not implement any new policies or otherwise engage in new labor practices while mediation is ongoing. During the mediation, the unions declined to accept wage cuts. Shortly thereafter, and still during mediation, Springfield hired Aroostook and Bangor Resources (ABR) (defendant) to perform switching work that the unions typically performed. Springfield was a wholly owned subsidiary of Guilford Transportation Industries, Inc. (Guilford). Guilford was closely held by four men. Three of those men were also the sole owners of ABR. Moreover, Springfield, Guilford, and ABR had the same four directors: the four owners of Guilford. In addition, the individual who initially reached out to ABR about the switching work was the “key player” in the negotiations that had failed. Finally, the ABR representative who decided that ABR would perform the switching was one of the owners of Guilford and directors of Springfield. The unions brought suit seeking to enjoin ABR from conducting the switching while the mediation with Springfield was ongoing. The district court granted the injunction. Springfield appealed.