Seitz v. International Brotherhood Teamsters

Background

James E. Seitz represented himself. He worked as an aircraft technician for United Airlines for thirty-two years and was a member of the International Brotherhood of Teamsters. A collective bargaining agreement governed his employment. Teamsters Local 986 was his local chapter, and Seitz alleged that both union entities were his certified bargaining representatives.

In August 2021, United announced a COVID-19 vaccination requirement for aircraft technicians. Employees with religious objections could request an accommodation by providing, within three days, a letter from a third party supporting their sincere religious beliefs. Seitz requested an accommodation based on his objection to vaccine ingredients and the use of cell lines originating from aborted fetal tissue. United denied the request because Seitz did not timely provide the third-party letter.

Seitz filed a union grievance seeking to use personal sick leave if he was removed from service because he remained unvaccinated. The union closed the grievance, telling him it was premature and that it would pursue the issue if United terminated him. Seitz later submitted the supporting letter, but United held him out of service and then terminated him on November 5, 2021, citing the vaccine policy and his late submission of the letter.

The union appealed the termination through the grievance process. A System Board of Adjustment—the final step identified in the grievance procedure—reviewed the case and denied the grievance. Seitz later requested arbitration with counsel of his choice, but a union representative denied that request based on the collective bargaining agreement.

Claims and motion

Seitz’s nine claims included two Title VII claims for religious discrimination, including failure to accommodate and retaliation; a claim for breach of the union’s duty of fair representation; claims under the Railway Labor Act concerning arbitration and other alleged rights; claims concerning contractual and statutory rights, honest-services fraud, bribery, and racketeering; and three additional honest-services-fraud claims against individual defendants.

The defendants moved to dismiss under Federal Rules of Civil Procedure 9(b) and 12(b)(6). Rule 12(b)(6) allows dismissal when a complaint does not adequately state a legally recognized claim. Rule 9(b) requires fraud allegations to describe the alleged misconduct with particularity, including who did what, when, where, and how. The defendants primarily argued that several claims were actually claims for breach of the union’s duty of fair representation and were barred by a six-month filing deadline. They also argued that other claims were inadequately pleaded or preempted by the Railway Labor Act.

Court’s analysis

The court held that claims one and two were independent Title VII claims and could be asserted separately from a fair-representation claim. The court therefore denied the motion to dismiss those claims.

The court dismissed claims four and five under the Railway Labor Act. It reasoned that Seitz had not been completely denied arbitration because the System Board of Adjustment hearing itself was an arbitration. The court also applied the six-month filing period for Railway Labor Act claims and found the claims untimely because the arbitration ended in January 2022 and the complaint was filed in April 2023.

The court dismissed claim six without prejudice as unintelligible. That claim combined allegations concerning contractual and statutory rights with honest-services fraud, bribery, and racketeering allegations related to contract negotiations in 2011, 2015, and 2016, without adequately explaining how the allegations related to the case.

The court dismissed claim three, the fair-representation claim, as untimely. The court explained that such claims generally must be filed within six months after the employee knew or should have known of the alleged breach. The court also noted that, if Seitz amended the complaint to assert a fair-representation claim, the claim could be asserted only against the International Brotherhood of Teamsters, according to the court’s discussion of the collective bargaining agreement.

The court dismissed claims seven through nine, which it liberally construed as civil racketeering claims. These claims concerned alleged payments and contract negotiations unrelated to United’s vaccine policy. The court dismissed them without prejudice because Seitz did not provide an exhibit that he cited as supporting his response to the defendants’ statute-of-limitations argument. The court also stated that any amended version would need to plead the alleged fraud with particularity and plausibly allege that the honest-services fraud proximately caused injury to Seitz’s property.

Disposition

The court granted the motion to dismiss in part. It dismissed all claims except the two Title VII claims without prejudice. The court ordered Seitz to file any amended complaint within twenty-eight days and to attach a marked comparison of the amended complaint against the current complaint. Judge Laurel Beeler stated that the order resolved the defendants’ motion to dismiss, docket entry 17.