Atlas Air, Inc. v. International Brotherhood of Teamsters

The DC Circuit affirmed the district court's issuance of a preliminary injunction enjoining a union's efforts to gain leverage over two commercial air carriers during negotiations over an amended collective bargaining agreement (CBA). The court held that the district court had jurisdiction to enter a status quo injunction in this major dispute, and did not abuse its discretion in enjoining this conduct.In light of the Railway Labor Act and the Norris- LaGuardia Act, the court held that Atlas presented compelling evidence in support of its assertion that this case involved a major dispute, because the existing CBA did not even arguably speak to whether the relevant conduct was permissible when done in furtherance of a particular goal. The court also held that Atlas demonstrated a likelihood of success on the merits, where Atlas showed that the status quo changed during a major dispute in violation of the RLA. The court held that the union encouraged strict compliance with the terms of the existing CBA in an effort to gain leverage in negotiations for a new or amended contract by encouraging pilots to block out on time, to make short notice sick calls, and to make filling open time more difficult. View "Atlas Air, Inc. v. International Brotherhood of Teamsters" on Justia Law