Andrews v. Louisville & Nashville R.R. Co
In Andrews v. Louisville & Nashville R.R. Co., 406 U.S. 320, 325, 92 S.Ct. 1562, 1565, 32 L.Ed.2d 95 (1972), an employee brought a state wrongful-discharge claim based squarely on an alleged breach of the collective bargaining agreement.
The Court held that Congress had intended the Railway Labor Act (RLA) dispute resolution to be mandatory for that type of dispute, and that courts were therefore foreclosed from addressing state claims that properly arise under the RLA.
In Andrews v. Louisville & Nashville R.R., 406 U.S. 320, 92 S.Ct. 1562, 32 L.Ed.2d 95 (1972), the specific question presented was whether a discharged railroad employee had to exhaust his administrative remedy of NRAB arbitration before commencing a civil action for wrongful discharge.
The Court noted that "exhaustion of remedies" is a misnomer because the federal administrative remedy is exclusive and does not allow post-exhaustion actions in another forum:
The term "exhaustion of administrative remedies" in its broader sense may be an entirely appropriate description of the obligation of both the employee and carrier under the Railway Labor Act to resort to dispute settlement procedures provided by that Act. It is clear, however, that in at least some situations the Act makes the federal administrative remedy exclusive, rather than merely requiring exhaustion of remedies in one forum before resorting to another. A party who has litigated an issue before the Adjustment Board on the merits may not relitigate that issue in an independent judicial proceeding. Union Pacific R. Co. v. Price, 360 U.S. 601, 79 S.Ct. 1351, 3 L.Ed.2d 1460 (1959). He is limited to the judicial review of the Board's proceedings that the Act itself provides. Gunther v. San Diego & A.E.R. Co., 382 U.S. 257, 86 S.Ct. 368, 15 L.Ed.2d 308 (1965). In such a case the proceedings afforded by 45 U.S.C. Sec. 153 First (i), will be the only remedy available to the aggrieved party. (Andrews, 406 U.S. at 325, 92 S.Ct. at 1565.)
In Andrews v. Louisville & Nashville R. Co., 406 U. S. 320 (1972), the Court held that a state-law claim of wrongful termination was pre-empted, not because the RLA broadly pre-empts state-law claims based on discharge or discipline, but because the employee's claim was firmly rooted in a breach of the CBA itself.
He asserted no right independent of that agreement:
"Here it is conceded by all that the only source of Andrews' right not to be discharged, and therefore to treat an alleged discharge as a `wrongful' one that entitles him to damages, is the CBA. . . . The disagreement turns on the extent of the railroad's obligation to restore Andrews to his regular duties following injury in an automobile accident. The existence and extent of such an obligation in a case such as this will depend on the interpretation of the CBA. Thus Andrews' claim, and the railroad's disallowance of it, stem from differing interpretations of the CBA. . . . His claim is therefore subject to the Act's requirement that it be submitted to the Board for adjustment." (Id., at 324.)