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Ramey v. District 141, International Association of Machinists and Aerospace Workers

378 F.3d 269 (2004)

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Ramey v. District 141, International Association of Machinists and Aerospace Workers

United States Court of Appeals for the Second Circuit

378 F.3d 269 (2004)

Facts

A group of airline mechanics (shuttle mechanics) (plaintiffs) worked for Eastern Airlines (Eastern) and were represented by the labor union District 141, International Association of Machinists and Aerospace Workers (association) (defendant). Right before Eastern went into bankruptcy, it sold a shuttle line to Trump Shuttle, and the shuttle mechanics began to work for Trump Shuttle. During the Eastern bankruptcy, the association argued that the shuttle mechanics had merely transitioned to Trump Shuttle rather than quitting and being rehired. Later, the shuttle mechanics became frustrated with the association and switched to a different union. However, Trump Shuttle experienced financial problems and sold the shuttle line to US Airways, Inc. (USAir). The shuttle mechanics’ new union was not allowed to represent the mechanics at USAir, and the association again became the shuttle mechanics’ labor representative. The mechanics for USAir’s main operations went on strike, but the shuttle mechanics’ separate collective-bargaining agreement prevented the shuttle mechanics from striking with the main-operation mechanics. After that dispute was resolved, USAir formally merged the shuttle mechanics into USAir’s main operations with its other mechanics. During the merger negotiations, contrary to its position in the Eastern bankruptcy, the association took the position that the shuttle mechanics had quit working for Eastern and had been rehired by Trump Shuttle. The association agreed that the shuttle mechanics’ postmerger start date would be the date on which they started working for Trump Shuttle, which gave the shuttle mechanics less seniority after the merger than if their Eastern time had also been included. A lower seniority status meant lower pay. In addition, some of the shuttle mechanics were furloughed because of their low seniority. The shuttle mechanics sued the association for breaching its duty of fair representation. The shuttle mechanics alleged that the association had treated them unfavorably in order to punish them for their earlier decision to change unions and their failure to join in the main-operations strike. The jury found that the association had advocated for the shorter seniority measurement out of hostility. The district court entered judgment for the shuttle mechanics, and the association appealed.

Rule of Law

Issue

Holding and Reasoning (Meskill, J.)

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