Northwest Airlines Corp. v. Association of Flight Attendants-CWA

In 2004, Northwest Airlines Corporation (Northwest) (plaintiff) began renegotiating collective-bargaining agreements (CBAs) with its employees’ unions. In 2005, Northwest filed for Chapter 11 bankruptcy. After the union representing Northwest’s flight attendants rejected a tentative agreement with Northwest regarding new employment terms and conditions necessary for Northwest’s reorganization, the bankruptcy court allowed Northwest to reject its CBA with the union and implement the tentative agreement’s terms. The flight attendants subsequently replaced their union with the Association of Flight Attendants (AFA) (defendant). When Northwest implemented the terms of the tentative agreement, as authorized by the bankruptcy court, AFA notified Northwest that AFA intended to strike to disrupt Northwest’s service. Northwest moved to enjoin AFA from striking, but the bankruptcy court denied the motion. Under the Railway Labor Act (RLA), once a CBA between a union and a carrier subject to the RLA becomes amendable, the carrier and the union must engage in renegotiation, and the parties are obligated to maintain the status quo until a new agreement is reached. The bankruptcy court found that Northwest’s rejection of the CBA and implementation of the terms of the tentative agreement unilaterally changed the status quo between the parties, which allowed the flight attendants to strike. The district court reversed and granted injunctive relief, holding that Northwest had not unilaterally changed the status quo and thus that AFA remained bound by the RLA’s status-quo-maintaining prohibition of striking. AFA appealed.