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.