A federal trial court in Michigan has held that an ERISA lawsuit brought by a former employee of Northwest Airlines is a minor dispute and is preempted by the Railway Labor Act (RLA). See James v. American General Assurance Co. (Sep. 8, 2011). Accordingly, the court held that it lacked jurisdiction to hear these claims and dismissed the lawsuit.

James, a former reservations agent for Northwest Airlines, was injured in a car accident and filed a claim for disability pension benefits under Northwest Airlines Pension Plan for Contract Employees (the "Pension Plan"). He also filed a claim for long-term disability benefits under Northwest Airlines Long Term Disability Plan ("LTD Plan"). Both claims were denied and James filed suit in federal court challenging the denials. Both the Pension Plan and the LTD plan requested the court dismiss the lawsuit for lack of subject matter jurisdiction, claiming these allegations constitute minor disputes that must be resolved pursuant to the RLA's dispute resolution mechanisms.