Executive Summary: In a unanimous decision, a panel of the United States Court of Appeals for the Ninth Circuit reversed a preliminary injunction arising out of an airline’s alleged violation of the status quo provisions of the Railway Labor Act (RLA). Int’l Bhd. Of Teamsters, Airline Division v. Allegiant Air, LLC, No. 14-16465 (9th Cir. June 8, 2015). The decision turned on whether an in-house “advocacy group” with which the airline had dealt on issues involving its pilots had become the pilots’ collective bargaining representative for purposes of the RLA, and whether work rules developed by the airline in coordination with the advocacy group constituted a “status quo” that the airline could not change unilaterally during its negotiations with the newly-certified representative of the pilots. The Ninth Circuit reversed the district court on both those points.
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