Kaufman v. Allied Pilots Association
United States Court of Appeals for the Fifth Circuit
274 F.3d 197 (2001)
- Written by Angela Patrick, JD
Facts
The Allied Pilots Association (association) (defendant) was the collective-bargaining group for pilots employed by American Airlines, Inc. (American). During a labor dispute with American, the association organized a pilot sick-out, i.e., the pilots pretended to be sick in order to miss work and pressure American to respond to their demands. Because the sick-out was an illegal strike in violation of the Railway Labor Act (RLA), a federal court ordered the pilots to return to work. Despite the order, the pilots continued the sick-out. The association was eventually ordered to pay American $45 million for damages caused by the association’s violation of the court’s order. The sick-out also negatively impacted over 300,000 airline passengers (plaintiffs). The passengers filed a class action against the association for damages caused by the sick-out. The district court dismissed all the passengers’ claims except a state-law claim for tortious interference that gave the passengers a state-law remedy that did not directly conflict with a provision in the RLA. The association appealed the district court’s decision to not dismiss the state-law tortious-interference claim, arguing that the claim was preempted under the Garmon-preemption doctrine.
Rule of Law
Issue
Holding and Reasoning (Higginbotham, J.)
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