Hawaiian Airlines v. Norris

Grant Norris (plaintiff) was an aircraft mechanic employed by Hawaiian Airlines, Inc. (Hawaiian) (defendant). While working on an airplane, Norris noted a damaged part and recommended replacing it. Instead, Norris’s supervisor attempted to fix the part. The supervisor then asked Norris to sign off on the repair and state that the airplane was safe to fly. Norris disagreed that the airplane was safe to fly and refused to sign the maintenance record. The supervisor suspended Norris. Norris reported his concern about the part to the Federal Aviation Administration (FAA). The FAA investigated and proposed revoking the supervisor’s license and imposing an almost $1 million fine against Hawaiian. The FAA matter eventually settled with Hawaiian paying a substantial fine. Hawaiian had a collective-bargaining agreement with its aircraft mechanics. Norris used the procedures set out in the agreement to contest his suspension, but Hawaiian ultimately terminated Norris for insubordination. Norris filed a lawsuit against Hawaiian for wrongfully discharging him in violation of a state public policy that protected whistleblowers. After lower courts dismissed each of Norris’s claims as preempted by the Railway Labor Act, the lawsuit ended up before the Hawaii Supreme Court. The Hawaii Supreme Court ruled that Norris’s wrongful-discharge claim was not preempted by the act. The United States Supreme Court agreed to review the issue.