Opinion · Supreme Court of the United States
Andrews v. Louisville & Nashville Railroad
406 U.S. 320
- Type
- Opinion
- Court
- Supreme Court of the United States
- Jurisdiction
- Federal
- Date
- 1972-05-15
- Topic
- general
How later courts describe this case
- holding that a claim is preempted by the RLA when the collective bargaining agreement is "'the only source of [the employee's] right not to be discharged"
- concluding that arbitration through the NRAB is mandatory and binding as to minor disputes
- holding that the plaintiffs state-law claim was not pre-empted because the RLA was a broad pre-emption of state law claims, but rather because the plaintiffs claim was firmly rooted in a breach of the CBA itself.
- holding that the arbitration provisions of section 153 First (i) are mandatory
- stating that “the very concept of ‘wrongful discharge’ implies some sort of statutory or contractual standard that modifies the traditional common-law rule that a contract of employment is terminable by either party at will”
- holding that RLA foreclosed petitioner’s wrongful discharge suit
- differing interpretations of collective bargaining agreements must be resolved through arbitration and not in federal courts
- overruling Moore v. Illinois Central Railway Co., 312 U.S. 630, 61 S.Ct. 754, 85 L.Ed. 1089 (1941)
Citator
Andrews v. Louisville & Nashville Railroad has been questioned or limited by later authorities: relies on overruled authority: 61 S. Ct. 754 (overruled by Andrews v. Louisville & Nashville Railroad). Read them before relying on it. 567 later decisions cite it.
- Authority status
- caution
- Cited by
- 567 opinions
- Distinguished
- 1 times
Headnotes
- Labor & Employment Law — Arbitration The grievance and arbitration procedures provided by the Railway Labor Act for the adjustment of minor disputes are compulsory rather than optional; the Act compels the parties to arbitrate such disputes before the National Railroad Adjustment Board, and the notion that these procedures may be availed of at the election of the employee or the carrier is neither good history nor good law. 404 U.S. 320, 322–323 (internal citations omitted)
- Labor & Employment Law — Railway Labor Act — Federal Nature of Employment Agreements An agreement required under § 204 of the Railway Labor Act is a federal contract governed and enforceable by federal law in the federal courts, and a railroad employee's claim for breach of an employment agreement is not a matter of state law. 404 U.S. 320, 323 (citing Machinists v. Central Airlines, 372 U.S. 682, 692 (1963))
- Labor & Employment Law — Exhaustion of Remedies — Railway Labor Act Where the compulsory character of an administrative remedy stems from a federal statute rather than from any contractual undertaking between the parties, the case for insisting on resort to those statutory remedies is stronger than where the remedy arises only under a labor agreement. 404 U.S. 320, 323
- Labor & Employment Law — Wrongful Discharge The fact that an employee characterizes his claim as one for "wrongful discharge" does not exempt it from the mandatory provisions of the Railway Labor Act for the processing of grievances, because the very concept of wrongful discharge implies a statutory or contractual standard modifying the traditional common-law rule that employment is terminable at will. 404 U.S. 320, 323–324
- Labor & Employment Law — Collective Bargaining Where the only source of an employee's right not to be discharged, and therefore to treat an alleged discharge as wrongful and entitling him to damages, is the collective-bargaining agreement, and the existence and extent of the employer's obligation turns on interpretation of that agreement, the employee's claim stems from differing interpretations of the collective-bargaining agreement and is subject to the Act's requirement that it be submitted to the Adjustment Board for adjustment; that the employee intends to seek employment elsewhere does not make the claim any less a dispute over interpretation of the agreement. 404 U.S. 320, 324
- Constitutional Law — Appellate Review — Questions Presented A constitutional question not set forth as a "question presented for review" in the petition for certiorari is precluded from the Court's consideration under Rule 23(1)(c); the Court does not reach constitutional questions not raised by the parties. 404 U.S. 320, 324–325 (citing Mazer v. Stein, 347 U.S. 201, 206 n.5 (1954))
- Labor & Employment Law — Railway Labor Act — Exclusivity of Administrative Remedy In at least some situations the Railway Labor Act makes the federal administrative remedy exclusive rather than merely requiring exhaustion of remedies in one forum before resorting to another; a party who has litigated an issue before the Adjustment Board on the merits may not relitigate that issue in an independent judicial proceeding and is limited to the judicial review of the Board's proceedings that the Act itself provides. 404 U.S. 320, 325 (citing Union Pacific R. Co. v. Price, 360 U.S. 601 (1959); Gunther v. San Diego & A. E. R. Co., 382 U.S. 257 (1965))
- Labor & Employment Law — Railway Labor Act — Overruling of Moore v. Illinois Central A railroad employee whose claim is subject to the Railway Labor Act must avail himself of the improved procedures afforded by the 1966 amendments, and in so holding the Court overrules Moore v. Illinois Central R. Co., 312 U.S. 630 (1941), which had held that an employee treating his employer's breach as a discharge was free to bring a state-law action for breach of contract without resorting to the Act's remedies. 404 U.S. 320, 325–326
Petitioner brought suit in the state trial court of Georgia seeking damages for alleged “wrongful discharge”
Moore held that a railroad employee who elected to treat his employer’s breach of the employment contract as a discharge was not required to resort to the remedies afforded under the Railway Labor Act for adjustment and arbitration of grievances, but was free to commence in state court an action based on state law for breach of contract. The result was supported by the Court’s conclusion that the procedures for adjustment of “minor
Later cases from this Court have repudiated the reasoning advanced in support of the result reached in Moore v. Illinois Central, supra. Fifteen years ago, in Brotherhood of Railroad Trainmen v. Chicago R. & I. R. Co., 353 U. S. 30, 39 (1957), this Court canvassed the relevant legislative history and said:
“This record is convincing that there was general understanding between both the supporters and the opponents of the 1934 amendment that the provisions dealing with the Adjustment Board were to be considered as compulsory arbitration in this limited field.”
When the issue was again before the Court in Walker v. Southern R. Co., 385 U. S. 196 (1966), it was observed:
“Provision for arbitration of a discharge grievance, a minor dispute, is not a matter of voluntary agreement under the Railway Labor Act; the Act compels the parties to arbitrate minor disputes before the National Railroad Adjustment Board established under the Act.” 385 U. S., at 198.
Thus, the notion that the grievance and arbitration procedures provided for minor disputes in the Railway Labor Act are optional, to be availed of as the employee or the carrier chooses, was never good history and is no longer good law.
In Republic Steel Corp. v. Maddox, 379 U. S. 650 (1965), the Court deduced from the Labor Management Relations Act a preference for the settlement of disputes in accordance with contractually agreed-upon arbitration procedures. It accordingly held that before a state court action could be maintained for breach of such a contract, the employee must first “attempt use of the contract grievance procedure agreed upon by employer and union as the mode of redress.” 379 U. S., at 652. In Maddox, the Court not only refused to extend Moore- to save state court actions for breach of contract under § 301 of the Labor Management Relations Act, but intimated that its rule might well not survive even in Railway Labor Act cases. Indeed, since the compulsory character of the administrative remedy provided by the Railway Labor Act for disputes such as that between petitioner and respondent stems not from any contractual undertaking between the parties but from the Act itself, the case for insisting on resort to those remedies is if anything stronger in cases arising under that Act than it is in cases arising under § 301 of the LMRA.
The fact that petitioner characterizes his claim as one for “wrongful discharge” does not save it from the Act’s
The constitutional issue discussed in the dissent was not set forth as a “question presented for review” in the
The term “exhaustion of administrative remedies” in its broader sense may be an entirely appropriate description of the obligation of both the employee and carrier under the Railway Labor Act to resort to dispute settlement procedures provided by that Act. It is clear, however, that in at least some situations the Act makes the federal administrative remedy exclusive, rather than merely requiring exhaustion of remedies in one forum before resorting to another. A party who has litigated an issue before the Adjustment Board on the merits may not relitigate that issue in an independent judicial proceeding. Union Pacific R. Co. v. Price, 360 U. S. 601 (1959). He is limited to the judicial review of the Board’s proceedings that the Act itself provides. Gunther v. San Diego & A. E. R. Co., 382 U. S. 257 (1965). In such a case the proceedings afforded by 45 U. S. C. § 153 First (i), will be the only remedy available to the aggrieved party.
In Walker v. Southern R. Co., 385 U. S. 196 (1966), the Court noted that there had been complaints not only about the long delay in processing of grievances on the part of the Adjustment Boards, but also about the fact that a more extensive right of judicial review of Board action was accorded to carriers than to employees. The Court noted that Congress, by Public Law 89-456, 80 Stat. 208, effective June 20, 1966, had legislated to correct these difficulties, but observed that the employee in Walker had not had the benefit of these new procedures. It therefore declined, “in his case,” 385 U. S., at 199, to overrule Moore. Petitioner Andrews, however, would in the prosecution of his claim before the Adjustment Board have the benefit of these
Affirmed.
Mr. Justice Powell took no part in the consideration or decision of this case.
References throughout the opinion to respondent are to the Georgia Railroad Co., which consisted of properties leased by Louisville & Nashville Railroad Co. and Seaboard Coastline Railroad Co. The petitioner alleged in his complaint that the Georgia Railroad Co. had refused to allow him to return to work.