Atlas Air, Inc. and Polar Cargo Worldwide, Inc. (collectively, "Atlas") won a victory in the Court of Appeals for the D.C. Circuit when the Court upheld a district court ruling enjoining the unions representing Atlas's pilots (the "Union") from encouraging strict compliance with the terms of their collective bargaining agreement with Atlas in an effort to gain leverage in contract negotiations.

In 2016 the Union notified Atlas that it planned to amend the collective bargaining agreement ("CBA") governing labor relations between the Union and Atlas. Thereafter, the union began a campaign promoting a series of actions to gain economic leverage in contract negotiations. The Union promoted "SHOP-ing," or "Stop Helping Out Purchase" (a reference to Atlas's headquarters in Purchase, New York) which, according to Union leaders, means that pilots should not "help out" Atlas by permitting it to get away with contract violations and should instead insist on "strict compliance with the contract." The Union specifically promoted several actions including "BOOT-ing," meaning "block out on time" (a reference to leaving the gate exactly on time rather than a few minutes early), short-notice sick calls, and refusing overtime.

The Court of Appeals held that, under the Railway Labor Act ("RLA"), the dispute was a "major dispute" because it "grew out of" the negotiation of a new or amended bargaining agreement. Because the dispute was a major one under the RLA, the Union could not alter the status quo by engaging in work slowdown or stoppage until the process for resolving a major dispute could be completed and any such change in status quo could be enjoined by the courts. The Court of Appeals also rejected the Union's contention that the Court did not have jurisdiction to issue an injunction to preserve the status quo under the Norris-Laguardia Act.

The court went on to affirm the district court's holding that BOOT-ing, SHOP-ing, short-notice sick calls, and refusing overtime altered the status quo based on statistics presented by Atlas showing that the occurrence of those actions increased after contract negotiations began. On that basis, the Court upheld the injunction against the Union.

The Court denied the Union's motions for rehearing and rehearing en banc. Atlas Air, Inc. v. Int'l Bhd. Of Teamsters, 928 F.3d 1102 (D.C. Cir. 2019), aff'g, 280 F. Supp. 3d 59 (D.D.C. 2017), reh'g denied, 2019 U.S. App. LEXIS 24255 (D.C. Cir., Aug. 14, 2019), reh'g en banc denied, 2019 U.S. App. LEXIS 24259 (D.C. Cir., Aug. 14, 2019).

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