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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Davis v. United Air Lines, Inc.

The plaintiff, Thomas Davis, a former "ramp serviceman" for United Air Lines, Inc., sued his employer following his dismissal due to a physical disability (epilepsy). He alleged wrongful dismissal in violation of Section 503 of the Rehabilitation Act of 1973, asserting a claim as a third-party beneficiary of a federal contract and a violation of a collective bargaining agreement which he claimed incorporated the Act's affirmative action provisions. Chief Judge Weinstein granted the defendant's motion to dismiss. The court ruled that there is no private right of action under Section 503, as established in a prior appeal concerning the same plaintiff (Davis v. United Air Lines, Inc.), and that allowing a third-party beneficiary claim would be inconsistent with the legislative scheme. Furthermore, the plaintiff's claim under the collective bargaining agreement was dismissed as he failed to exhaust the mandatory Railway Labor Act procedures, and his "futility" argument was rejected.

Rehabilitation ActWrongful DismissalThird-Party BeneficiaryCollective Bargaining AgreementDisability DiscriminationRailway Labor ActMotion to DismissPrivate Right of ActionFederal Contract LawAffirmative Action
References
20
Case No. 13-10-00247-CV
Regular Panel Decision
Jul 29, 2010

Unit Texas Drilling, LLC, Unit Drilling Company and Cliff Welker v. Caesar Morales, Jr. and Rhonda Morales

This memorandum opinion from the Thirteenth District of Texas Court of Appeals addresses an appeal by Unit Texas Drilling, LLC, Unit Drilling Company, and Cliff Welker. They sought to reverse a trial court's order denying their motion to compel arbitration in a personal injury suit filed by Caesar Morales, Jr. and Rhonda Morales. The Moraleses' claims arose from Caesar's on-the-job injury while working for Unit Texas, a non-subscriber to the Texas Workers Compensation Act, and concerned a mandatory 'Occupational Injury Benefit Plan' with an arbitration clause. The appellate court found that the Federal Arbitration Act applied, the arbitration agreement was valid and enforceable, and rejected the appellees' defenses, including arguments related to the McCarran-Ferguson Act, Texas Labor Code provisions, unconscionability, and failure of consideration. Consequently, the court reversed the trial court's order and remanded the case for further proceedings.

Arbitration AgreementFederal Arbitration ActTexas Workers Compensation ActNon-subscriber EmployerMotion to Compel ArbitrationUnconscionability DefenseMcCarran-Ferguson ActIllusory PromiseContractual DisputesEmployment Law
References
46
Case No. MISSING
Regular Panel Decision

United Transportation Union v. DELAWARE AND HUDSON RAILWAY, CO.

This case addresses a labor dispute between the United Transportation Union (UTU), Delaware & Hudson Railway Company (D & H), and the National Mediation Board (NMB) under the Railway Labor Act. UTU sought declaratory and injunctive relief, asserting its right to self-help (strike) after purportedly terminating collective bargaining negotiations with D & H. The NMB intervened, attempting to compel mediation, which UTU resisted, claiming NMB lacked jurisdiction due to proper termination of conferences. The Court, denying UTU's motion for summary judgment, clarified that while mutual termination is not required, an unequivocal termination and good faith bargaining are prerequisites for exercising self-help. Ultimately, the court found genuine issues of material fact existed regarding both the unequivocal termination of conferences and UTU's good faith bargaining efforts, thus precluding summary judgment.

Railway Labor ActCollective BargainingNegotiation TerminationSelf-HelpMediationSummary JudgmentGood Faith BargainingLabor DisputeFederal Rules of Civil Procedure
References
18
Case No. MISSING
Regular Panel Decision

Douds v. Local 24368, United Wire & Metal Workers Union

The National Labor Relations Board (NLRB) filed a petition for an injunction against Local 24368, United Wire and Metal Workers Union, A.F.L., alleging unfair labor practices. This action followed a dispute where Local 365, UAW-CIO, initially certified as the bargaining agent for Abko Products, Inc. employees, attempted to waive its authority in favor of Local 24368 through an agreement, subsequently ratified by the employees. Abko Products, Inc. refused to bargain with Local 24368, leading to a strike and picketing. The court determined the agreement between the unions was void as a certified bargaining agent cannot delegate its authority and employee ratification via signed papers does not validate such an assignment. Ultimately, the court denied the injunction, finding it neither just nor proper, suggesting the issue was best suited for administrative resolution by the NLRB.

Labor LawInjunction DenialUnfair Labor PracticesCollective BargainingUnion CertificationDelegation of Bargaining AuthorityEmployee RatificationStrike ActionPicketingNational Labor Relations Act
References
0
Case No. 1:96-CV-337
Regular Panel Decision
Dec 28, 1998

Saint Paul Fire & Marine Insurance v. United States

Seaman Christopher Gray sustained injuries at the Chickamauga Lock and Dam. Serodino, Inc., Gray's employer, and its insurer, Saint Paul Fire and Marine Insurance Company, initiated a lawsuit against the United States of America and the United States Army Corps of Engineers, seeking contribution or indemnity related to Gray's injuries. The plaintiffs asserted admiralty jurisdiction over their claims. The United States filed a Motion for Summary Judgment, contending that the court lacked subject matter jurisdiction. The court determined that the plaintiffs failed to comply with the administrative filing requirement of the Admiralty Extension Act and that Gray's underlying admiralty claim against Serodino did not confer admiralty jurisdiction over the plaintiffs' claims against the United States. Consequently, the court granted the United States's Motion for Summary Judgment, citing a lack of subject matter jurisdiction.

Admiralty jurisdictionSovereign immunitySuits in Admiralty ActAdmiralty Extension ActContributionIndemnificationSummary judgmentJones ActMaritime lawNavigable waters
References
18
Case No. MISSING
Regular Panel Decision

Wilson & Co. v. United Packinghouse Workers

An employer initiated a lawsuit seeking $50,000 in damages against the United Packinghouse Workers of America and other labor organizations for an alleged breach of a collective bargaining agreement, citing strikes and work stoppages in New York in March 1948. The defendants moved to dismiss the action, challenging the court's subject matter and personal jurisdiction, and arguing that Section 301(a) of the Labor Management Relations Act was unconstitutional. They contended it exceeded Article III, Section 2 limitations, infringed upon the Tenth Amendment, and violated the Fifth Amendment's due process clause through discriminatory application to unincorporated labor organizations and improper service of process. The court, however, denied all motions. It affirmed that Congress, under the Commerce Clause, constitutionally created substantive federal rights for enforcing collective bargaining agreements and validly established federal jurisdiction and procedural rules for such suits, including service of process on labor organizations.

Labor LawCollective Bargaining AgreementBreach of ContractFederal JurisdictionConstitutional LawDue ProcessCommerce ClauseTenth AmendmentFifth AmendmentLabor Management Relations Act
References
26
Case No. MISSING
Regular Panel Decision
Mar 27, 1985

United States v. $100 in United States Currency

The United States initiated an in rem forfeiture action against $100,000 in U.S. currency, alleging it originated from illegal drug transactions. Claimants Jose Martinez-Torres and Nancy Medina asserted the funds were legitimate lottery winnings. The government sought summary judgment, arguing issue preclusion from a prior Nebbia bail hearing where Medina's lottery claim was found incredible. The Court granted partial summary judgment for the government, establishing probable cause for forfeiture. However, it denied the application of offensive collateral estoppel for full summary judgment, citing the distinct procedural environment and limited scope of the Nebbia hearing, and ruled that claimants are entitled to a plenary trial to prove the legitimate source of the funds.

ForfeitureDrug Trafficking ProceedsCollateral EstoppelIssue PreclusionSummary JudgmentProbable CauseIn Rem ForfeitureBail HearingDue Process ConcernsPuerto Rican Lottery
References
8
Case No. CIV-88-1404C, CIV-90-481C
Regular Panel Decision

CSX Transportation, Inc. v. United Transportation Union

CSX Transportation, Inc. (CSXT) initiated the sale of a 369-mile rail line, which threatened the jobs of 226 employees. In response, the United Transportation Union and American Train Dispatchers Association (the Unions) invoked the Railway Labor Act (RLA) § 6, seeking to negotiate labor-protective provisions and preserve the status quo. The district court initially deemed the dispute 'minor' due to CSXT's plausible contractual defense, allowing the sale to proceed while the matter went to arbitration. A special adjustment board subsequently found CSXT's contractual defense unavailing, concluding that existing agreements did not permit the sale without prior bargaining over employee impacts. This court affirmed the board's jurisdiction and its finding, clarifying that the Unions were indeed entitled to status quo preservation during such bargaining, distinguishing its ruling from other circuits that had broadened management prerogative in partial business sales. The case is now remanded to the board to determine the appropriate remedies for the affected union members.

Railway Labor ActLabor DisputeCollective BargainingStatus QuoLine SaleArbitrationMajor DisputeMinor DisputeManagement PrerogativeEmployee Protection
References
51
Case No. MISSING
Regular Panel Decision

Block Coal & Coke Co. v. United Mine Workers

This dissenting opinion addresses a claim for unemployment compensation benefits by thousands of coal miners (United Mine Workers of America, District No. 19) against their employers, the Block Coal and Coke Company and other coal operators, for the period of April 1 to May 8, 1939. The core legal question is whether their unemployment stemmed from a 'labor dispute' under Tennessee law, which would disqualify them from benefits. The Commissioner of Labor initially granted benefits, reversed by the Board of Review, then reinstated by the Chancery Court. The coal operators appealed. Justice DeHaven dissents, arguing that the unemployment was due to the expiration of a collective bargaining agreement and ongoing negotiations, not an active labor dispute. He contends that deeming negotiations a dispute would undermine collective bargaining and that the statute requires a localized labor activity like a strike or lockout at the workplace. He concludes that the chancellor's decision to allow benefits should have been affirmed, implying the majority denied the benefits.

Unemployment CompensationLabor DisputeCollective BargainingContract ExpirationStatutory InterpretationTennessee Unemployment Compensation LawWorkers' RightsEmployer-Employee RelationsAppellate CourtDissenting Opinion
References
6
Case No. MISSING
Regular Panel Decision

Fraternal Order of Police, National Labor Council, USPS No. 2 v. United States Postal Service

The Fraternal Order of Police (FOP) and 13 individual Postal Police Officers sued the United States Postal Service and its employees, alleging violations of federal and state law, as well as their employment contract. Plaintiffs challenged restrictions on their law enforcement authority, citing 40 U.S.C. § 318, and also claimed illegal locker searches under the Fourth Amendment and New York law. The defendants sought dismissal, primarily arguing a lack of subject matter jurisdiction and the plaintiffs' failure to exhaust administrative remedies. The court granted the defendants' motion, dismissing the claims. It ruled that Section 318 does not confer a private right of action and that the plaintiffs failed to exhaust the grievance procedures outlined in their collective bargaining agreement and the Postal Reorganization Act for their search and contract-related claims.

Labor LawPostal ServicePolice PowersFourth AmendmentLocker SearchCollective Bargaining AgreementExhaustion of RemediesPrivate Right of ActionSubject Matter JurisdictionMotion to Dismiss
References
51
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