Bybee v. International Brotherhood of Teamsters

Background

Kevin E. Bybee and other United Airlines mechanics sued the International Brotherhood of Teamsters, individual union officers, United Airlines, and related entities. The second amended complaint contained 619 paragraphs, 111 pages, 10 claims, and 25 proposed items of relief.

The plaintiffs’ allegations centered on LOA 05-03M, the union’s handling of related grievances, and the plaintiffs’ alleged exclusion from the Continental Airlines Retirement Plan (CARP) as of October 1, 2010. The plaintiffs asserted claims for breach of contract, breach of the union’s duty of fair representation, violation of Railway Labor Act § 184, breach of fiduciary duty under Labor-Management Reporting and Disclosure Act § 501, and six claims under the Employee Retirement Income Security Act.

Personal jurisdiction over Stripling and Miranda

Paul Stripling and George Miranda moved under Federal Rule of Civil Procedure 12(b)(2) to dismiss for lack of personal jurisdiction. They argued that they lacked sufficient contacts with California. The plaintiffs argued that federal statutes and California’s long-arm statute supported jurisdiction, and that Stripling and Miranda directed activities concerning grievances to California.

The court held that the plaintiffs had made a prima facie showing of personal jurisdiction. Because factual conflicts at this stage had to be resolved in the plaintiffs’ favor, the court denied Stripling’s and Miranda’s Rule 12(b)(2) motion. The plaintiffs’ motion for jurisdictional discovery was terminated as moot.

Counts I and II: contract and fair-representation claims

The court dismissed Count I, the breach-of-contract claim against United, and Count II, the duty-of-fair-representation claim against the union defendants.

The court explained that airlines are governed by the Railway Labor Act and that a hybrid claim against an employer and a union is subject to a six-month limitations period. It concluded that the plaintiffs’ fair-representation allegations were untimely. The plaintiffs stated that they learned of the alleged abandonment of LOA 05-03M in August 2016 and identified March 2017 as the earliest date related to the grievance allegations, but they did not file suit until October 31, 2018. The court also relied on its earlier conclusion that the grievance-related allegations did not plausibly state a fair-representation claim.

The court gave several reasons for dismissing the contract claim against United. It said that dismissal of the fair-representation claim supported dismissal of the related employer claim. It also concluded that a claim based on United’s alleged collusion with the union was not legally cognizable, and that claims requiring interpretation of the collective bargaining agreement were preempted by the Railway Labor Act and subject to the Act’s dispute-resolution system.

Count III: alleged statutory due process under Railway Labor Act § 184

The court dismissed Count III. To the extent the claim challenged the union’s failure to support the plaintiffs’ grievances, the court treated it as duplicating the fair-representation claim and rejected it for the same reasons. The court also declined to imply a private right of action against the union and United to enforce the plaintiffs’ asserted right under § 184 to proceed to arbitration over the union’s objections.

Count IV: fiduciary-duty claim under Labor-Management Reporting and Disclosure Act § 501

The plaintiffs asserted this claim against individual union officers, including James P. Hoffa, Finn, Griswold, Stripling, and Miranda. The court said the claim largely repeated allegations that the union failed to fulfill its duty of fair representation and that union officers could not be held personally liable for union actions in the circumstances described.

The court had previously dismissed the claims against Hoffa as insufficiently specific. It concluded that the new allegations remained deficient because they relied on unsupported factual deductions and unreasonable inferences. The opinion’s discussion of Count IV ends by stating, “Count III is dismissed.” The text therefore contains an apparent count-numbering error, although the section addresses the Count IV fiduciary-duty claim.

Counts V through X: ERISA claims

The court dismissed Counts V, VI, VII, VIII, IX, and X. It concluded that the claims, despite being framed under ERISA, all ultimately challenged the plaintiffs’ alleged failure to be enrolled in CARP as of October 2010. The court determined that deciding eligibility required interpreting the collective bargaining agreement. It therefore found that the claims were deficient for the reasons stated in its earlier dismissal order and that Railway Labor Act procedures governed disputes requiring collective-bargaining-agreement interpretation.

Disposition

The court dismissed the second amended complaint, declined to grant further leave to amend, and terminated the plaintiffs’ discovery dispute letter as moot. The order expressly states that the second amended complaint was dismissed with prejudice and that judgment would be entered for the defendants.