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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.

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Holding and Reasoning (Higginbotham, J.)

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