Second Circuit Holds That Employees Do Not Have Private Cause of Action Under the Railway Labor Act

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Earlier this week, the federal Second Circuit Court of Appeal affirmed the Eastern District of New York's dismissal of the Railway Labor Act ("RLA") and state law claims that had been filed by former American Airlines flight attendants against American Airlines and their union.

In Lindsay v. Association of Professional Flight Attendants et al., the plaintiffs alleged that a 2003 restructuring agreement between American Airlines and the union violated sections 1 and 7 of the RLA because the union unlawfully replaced the 2001 collective bargaining agreement previously entered into between American Airlines and the union. The plaintiffs also alleged certain state law claims.

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