Burlington Northern & Santa Fe Railway Co. v. Brotherhood of Maintenance of Way Employees

The Railway Labor Act, 45 U.S.C. § 151, et seq., (RLA) regulates in great detail the relationship between railroads and the unions which represent railway employees. Section 152 First of the RLA provides that carriers and their employees have a duty “to exert every reasonable effort ... to settle all disputes ... in order to avoid any interruption to commerce or to the operation of any carrier growing out of any dispute between the carrier and the employees thereof.” Because I conclude that a court has no authority to add to that duty a requirement that a railway union provide advance notice…