Supreme Court of the United States

Hawaiian Airlines, Inc. v. Norris

June 20, 1994512 U.S. 246

Summary

Justice Blackmun delivered the unanimous opinion affirming the Supreme Court of Hawaii. The Court held that the Railway Labor Act does not pre-empt Norris’s state-law public-policy and whistleblower claims because those claims enforce rights independent of his collective-bargaining agreement and require only factual inquiries into discharge and retaliatory motive. It adopted Lingle’s contract-interpretation standard for RLA pre-emption and explained that Conrail’s “arguably justified” test distinguishes major from minor contractual disputes, rather than determining whether independent state-law claims fall within the RLA. There were no separate opinions.

Holding

  • The standard governing RLA pre-emption of state-law claims.. The RLA does not pre-empt state-law claims involving rights and obligations independent of a collective-bargaining agreement. Lingle’s standard, under which pre-emption depends on whether resolving the claim requires interpreting the agreement, applies to RLA cases.
  • The applicability of Conrail’s “arguably justified” standard.. The “arguably justified” standard distinguishes major from minor disputes already governed by the RLA; it does not determine whether a dispute falls within the RLA in the first place.
  • Whether Norris’s wrongful-discharge claims are pre-empted.. Norris’s claims for discharge in violation of public policy and Hawaii’s Whistleblower Protection Act are not pre-empted by the RLA.

Docket 92-2058

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