The Regional Airline Pilots Association James Bishop v. Wings West Airlines, Inc., Dba American Eagle

HUG, Circuit Judge:

The central issue in this case is whether the airline's unilateral change in working conditions, immediately after the union’s certification as representative of the airline’s employees but before the collective bargaining process had begun, was a violation of section 2, First through Fourth of the Railway Labor Act (“RLA”), 45 U.S.C. § 152, First through Fourth (1982). The change in working conditions involved a change in travel pass privileges. The district court held that because this was a “minor dispute” to which the arbitration provisions of the RLA applied, it lacked…