Air Line Pilots Association, International v. O'Neill

PETITIONER: Air Line Pilots Association, International
RESPONDENT: O'Neill
LOCATION: The Department of Health and Human Services

DOCKET NO.: 89-1493
DECIDED BY: Rehnquist Court (1990-1991)
LOWER COURT: United States Court of Appeals for the Fifth Circuit

CITATION: 499 US 65 (1991)
ARGUED: Jan 14, 1991
DECIDED: Mar 19, 1991

ADVOCATES:
Laurence E. Gold - on behalf of the Petitioner
Marty Harper - on behalf of the Respondents

Facts of the case

Question

Media for Air Line Pilots Association, International v. O'Neill

Audio Transcription for Oral Argument - January 14, 1991 in Air Line Pilots Association, International v. O'Neill

Audio Transcription for Opinion Announcement - March 19, 1991 in Air Line Pilots Association, International v. O'Neill

William H. Rehnquist:

The opinion of the Court in No. 89-1493, Airline Pilots Association International versus O'Neill will be announced by Justice Stevens.

John Paul Stevens:

This case comes to us on a writ of certiorari from the United States Court of Appeals for the Fifth Circuit.

It arose out of a bitter labor dispute between Continental Airlines and the petitioner, Airline Pilots Association International, the Union that represented the Continental's pilots.

Respondents are a group of pilots who are dissatisfied with petitioner's settlement of the unsuccessful strike against Continental.

Contending that petitioner's settlement of the strike resulted in less favorable terms for striking pilots and the Union could have achieved by a unilateral decision simply to return to work.

Respondents sued petitioner for, among other things, breach of the Union's duty of fair representation.

Respondents argued that petitioner had breached that duty by arbitrarily settling the strike in an incompetent manner.

The District Court granted summary judgment to petitioner; the court ruled that there was no evidence that petitioner had acted in bad faith or had discriminated against any of its constituents.

The court held that the duty of fair representation does not protect Union members against inadequate representation so long as the Union has acted in good faith and not discriminated.

The Court of Appeals reversed.

It held that the duty of fair representation has three distinct components.

The Union breaches the duty if its conduct is either discriminatory, taken in bad faith, or arbitrary.

The court held that a jury could find that petitioner's conduct was arbitrary because it could find that the petitioner had settled the strikes on terms that were less favorable than could have achieved by simply terminating the strike.

We now reverse the Court of Appeals.

We hold that the court was correct in ruling that the Union breaches its duty if its actions whether made in the course of processing grievances or negotiating agreements are either arbitrary, discriminatory, or in bad faith.

We conclude, however, that the court committed error in its elaboration and application of the arbitrariness component of the fair representation duty.

The Union's actions are arbitrary only if in light of the factual and legal landscape at the time of the actions, the Union's behavior is so far outside a wide range of reasonableness that it can fairly be called irrational.

The mere fact that, in retrospect, petitioner's settlement of the strike proved less advantageous, and abandonment of the strike does not mean that the Union acted irrationally in securing the settlement.

The legal consequences of the unilateral return to work were not clearly established at the time of the settlement and the agreement avoided potentially lengthy and conceivably unsuccessful litigation.

Our opinion is unanimous.