00-2349 Brown v. Illinois Central Railroad Company

By: dmc-admin//June 25, 2001//

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“[A] bright-line rule that the RLA does not preclude claims brought under other federal statutes cannot be reconciled with the requirement that when conducting a preclusion inquiry a court must examine each federal statute to determine the effect that Congress intended the statutes to have upon each other. Thus, we decline to hold that the RLA’s preclusive effect is determined in each case entirely by the source of the right asserted in the plaintiff’s claim. It remains true as a general rule that the RLA will not bar a plaintiff from bringing a claim under an independent federal statute in court (because such claims are generally independent of the CBA and will be adjudicated under non-CBA standards). However, this rule no longer applies if the federal claim asserted by the plaintiff depends for its resolution on the interpretation of a CBA. Such claims are not ‘independent’ of the CBA regardless of their source, and are therefore precluded by the RLA.”

Affirmed.

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