In Atchison, Topeka and Santa Fe Railway Co. v. Buell, U.S. 107 S.Ct. 1410, 94 L.Ed.2d 563 (1987), the Supreme Court considered whether the availability of a labor grievance procedure under the Railway Labor Act (RLA), 44 Stat. 577, as amended, 45 USC 151 et seq., deprived an employee of his right to bring an action under the Federal Employers' Liability Act (FELA), 45 USC 51 et seq. The Court held that the availability of arbitration under the RLA did not bar an employee from bringing an FELA action. The rationale for the Court's decision was that although strong policies encourage arbitration, different considerations apply where an employee's claim arises out of a special statute such as the FELA, which is designed to provide minimum substantive guarantees to individual workers. 107 S.Ct. at 1415.