Anderson v. Metro-North Commuter Railroad Company

Background

Steven Anderson brought a hybrid action under the Railway Labor Act against his former employer, Metro-North Commuter Railroad Company, and his former union, International Brotherhood of Teamsters Local 808. He alleged that Metro-North breached its collective bargaining agreement (CBA) by terminating him on June 4, 2014, and that Local 808 breached its duty to fairly represent him afterward. Both defendants moved for summary judgment, which asks whether the evidence presents a genuine dispute requiring a trial.

The CBA required an employee who could not report for work to notify a supervisor. It also provided that, except for sickness, disability, or circumstances beyond the employee’s control, an employee absent for more than 14 consecutive days without permission would lose all seniority. The parties agreed that losing seniority terminated the employee’s employment. Another provision stated that references to numbers of days meant calendar days unless otherwise specified.

Anderson had approved intermittent leave under the Family and Medical Leave Act, but the court found that he had used all 480 hours of that leave by March 18, 2014. From May 21 through June 3, 2014, he did not report for any of his 11 scheduled shifts. Metro-North’s records and Anderson’s cellphone records did not show that he contacted a designated point of contact or anyone else at Metro-North during that period. Metro-North then sent him a June 4 letter stating that he had forfeited his seniority rights under Rule 28.

Metro-North Claim

The court rejected Anderson’s argument that Rule 28 applied only to 14 consecutive workdays. It held that the CBA’s express reference to calendar days controlled. Anderson was absent from May 21 through June 3, a period of 14 calendar days, and was notified on June 4, the fifteenth calendar day, that he had been absent without permission since May 21. The court therefore concluded that his absence exceeded the rule’s 14-day threshold.

The court also found no genuine dispute about whether Anderson notified Metro-North during the relevant period. His May 13 and May 15 voicemails to Tracy-Ann Jeffers did not state that he would be absent from May 21 through June 3, and he did not request additional leave in those messages. The court found that the doctor’s notes did not establish that Anderson delivered them to Metro-North or Local 808 before his termination. It also concluded that evidence concerning corrections to earlier absence codes and concerns about recordkeeping did not show that Anderson contacted Metro-North during the period that resulted in his termination.

The court held that no reasonable juror could find that Metro-North’s termination of Anderson violated the CBA. It dismissed Anderson’s breach-of-contract claim against Metro-North.

Local 808 Claim

The parties agreed that Anderson’s claim against Local 808 could not succeed without a valid claim that Metro-North breached the CBA. Because the court dismissed the claim against Metro-North, it also dismissed Anderson’s claim against Local 808.

Disposition

The court granted the defendants’ motions for summary judgment, directed the Clerk of Court to terminate the motions, and ordered the case closed.