A federal district court judge granted partial summary adjudication to SkyWest Airlines, Inc., holding that a former employee’s claims under California wage and hour laws are pre-empted by federal law. Specifically, the court found that the former employee is not entitled to California’s daily overtime and meal and paid rest periods because they conflict with federal law – Railway Labor Act (RLA), 45 U.S.C. § 151-88.
Tiffany Blackwell, a former customer service representative for SkyWest, sought relief for multiple alleged violations of state law including claims that SkyWest failed to compensate her for daily overtime hours and provide her with meal and paid rest periods. SkyWest countered that Ms. Blackwell was a member of SkyWest Airlines’ Frontline Association (SAFA) and was subject to SkyWest-SAFA’s negotiated collective employee contract, which governed the terms of her employment.
Regarding her overtime claims, Ms. Blackwell alleged that SkyWest violated California’s Wage Order 9 by failing to pay her daily overtime based on alternative work schedule rules and shift trades. The court disagreed, holding that where state law claims require a court to interpret the terms of a collective bargaining agreement (CBA), those claims are pre-empted under the RLA. This is because the RLA provides a mechanism for settling labor-management disputes - both major and minor disputes.
The court explained that Ms. Blackwell’s argument ran counter to congressional intent. Notably, in determining whether the provisions in question violated state law, the court would have to construe the CBA under state law principles. The court cautioned that doing so could increase uncertainty and dissent among parties in labor negotiations and undermine federal labor laws.
The court found Ms. Blackwell’s state law claims were “‘inextricably intertwined’ with the meaning of terms in the CBA.” The SkyWest-SAFA CBA contained express provisions concerning overtime, shift trades and meal and rest periods. Therefore, the court’s inquiry into Ms. Blackwell’s state law claims would require the court to impermissibly interpret the CBA’s terms according to California law.
The court further held that even state law disputes that invoke an implicit term of a CBA are likewise pre-empted by federal law. An implied term can arise from practices, usage and customs under the agreement. At issue were meal and rest periods not specifically addressed under the SkyWest-SAFA CBA. SkyWest argued that state meal and rest period requirements may conflict with federal aviation and security regulations, including the Airline Deregulation Act. Those regulations, in certain instances, conflicted with California’s meal and rest period requirements. SkyWest asserted that because compliance with federal aviation and security regulations was not optional, these regulations were implicitly part of the parties’ CBA. The court agreed and found that resolution of Ms. Blackwell’s meal and rest period claims would require it to interpret the CBA’s terms under state law. It noted that doing so not only violated congressional intent, but could subject SkyWest to “‘inconsistent interpretations in different jurisdictions.’” The court granted summary adjudication in SkyWest’s favor on the state meal and rest period claims.
While there are very few rulings that have held California’s wage and hour laws are pre-empted by federal law, the application of this ruling outside the heavily regulated airline industry is yet unknown. The decision is by a trial court and not considered binding authority for other cases; however, the decision is decidedly a large victory for SkyWest. Moreover, it will provide other airline industry employers and other employers subject to incongruent federal directives and state law with an even stronger argument, under the RLA, that they are not required to comply with California state wage and hour laws, including meal and rest period requirements.
This blog entry was authored by Stacey James and Tina Winston.
On July 30, 2010, Illinois Governor Pat Quinn signed 