Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

Appellant and appellee entered into two collective bargaining agreements ("2002 Agreement" and "2006 Agreement") covering retiree healthcare benefits that contained dispute resolution procedures. Appellant brought a suit to compel appellee to arbitration pursuant to the Labor Management Relations Act, 29 U.S.C. 185, and 28 U.S.C. 1337, when appellee unilaterally modified certain retirees' healthcare coverage in October 2008. Before the district court ruled on the motion, appellee again unilaterally modified the health care coverage wherein appellant filed another grievance under the 2002 and 2006 Agreements and amended its first complaint to include the grievance. At issue was whether the district court properly dismissed the complaint for failure to state a claim. The court held that the district court properly dismissed the amended complaint where the district court concluded that the matters were not arbitrable because they occurred after the agreements terminated and were thus not within the scope of arbitrability as defined by Article XI, Section 4.

Trans State Airlines, LLC ("TSA") appealed the district court's grant of summary judgment to Air Line Pilots Association International ("ALPA") enforcing an arbitrator's award of backpay to a pilot after TSA fired him. At issue was whether the award violated public policy against large loans to union officials embodied in the Labor Management Reporting and Disclosure Act ("LMRDA"), 29 U.S.C. 401-531. After concluding that TSA had standing to pursue an appeal and that the arbitrator's unreviewed decision in a prior arbitration did not preclude TSA's public policy challenge, the court held that the lack of control, combined with the purpose and structure of the section 60 payments in ALPA's Administrative Manual, weighed against finding the payments were an illegal loan.