COA Finds Employment Claims Barred by Union Agreement

In Williams v. American Eagle Airlines, the North Carolina Court of Appeals addressed the interplay between union contracts and employment claims. In this case, the plaintiff had been a part-time fleet service clerk for American Eagle, where she was a member of the Transport Worker's Union, and was covered by a collective bargaining agreement. She also had a full-time administrative position at Duke. In 2006, the plaintiff injured her shoulder while moving luggage, started receiving workers' compensation benefits, and eventually had surgery. Following surgery, plaintiff resumed her duties at Duke, but did not return to American Eagle, apparently with representations that should not return to work at all. Because of this inconsistency, American Eagle terminated her for dishonesty related to her workers' compensation.

Rather than file a grievance through the Union, the plaintiff filed suit in state court, alleging claims for (1) breach of contract because she was fired without just cause; and (2) violation of the the North Carolina Retaliatory Employment Discrimination Act (“REDA”) because her termination was cause by her use of workers' compensation. At trial, the jury ruled against the plaintiff on the REDA claim, but found in her favor on the contract claims and awarded damages.

On appeal, the Court vacated the verdict because the contract claims were legally barred. "When an employee’s claim is firmly rooted in a breach of a collective bargaining agreement and asserts no rights independent of that agreement, such claim is preempted by the Railway Labor Act (RLA)." (The RLA governs unions in the airline industry.) In other words, when an employee wants to challenge her termination as unlawful under a CBA, she usually must pursue the matter through the CBA's grievance mechanism instead of in court. As this plaintiff did that, the breach of contract claims were legally barred, and the verdict had to be vacated.