## Facts

- Two railroad unions (BLE and UTU) had a 1995 collective bargaining agreement with Springfield Terminal Railway Company governing engineers, conductors, and trainmen.
- The agreement included a broad work-assignment provision requiring union-represented employees to perform services under the carrier’s direct control related to train make-up, car and train movement over carrier trackage, and servicing industrial sidings.
- Springfield was a railroad carrier under the Railway Labor Act (RLA) and a wholly owned subsidiary of Guilford Transportation Industries, Inc., a closely held company.
- Aroostook and Bangor Resources, Inc. (ABR) was a wood-products company owned and controlled by individuals who also owned and directed Guilford; Springfield, Guilford, and ABR shared interlocking directors.
- Springfield sought wage concessions from the unions; negotiations failed and the dispute entered RLA mediation, triggering statutory “status quo” obligations barring unilateral changes in working conditions while procedures continued.
- During mediation and after the unions refused wage cuts, Springfield arranged for ABR to perform switching work for certain Springfield customers that had historically been performed by Springfield’s union employees.
- The unions sued, alleging Springfield was using ABR to divert bargaining-unit work and to evade the agreement and the RLA’s status quo requirements; the district court characterized the controversy as a major dispute and enjoined ABR from performing the switching work pending completion of RLA procedures.

## Issues

1. Whether Springfield’s reassignment of switching work to ABR presented a “major” dispute under the RLA, rather than a “minor” dispute about contract interpretation.
2. Whether a formally non-carrier affiliate (ABR) could be bound by an RLA status quo injunction when the carrier used it to perform work covered by the collective bargaining agreement.
3. Whether the evidence supported injunctive relief barring ABR’s switching services to preserve or restore the status quo during RLA mediation.

## Decision

- The First Circuit affirmed the district court’s judgment and injunction.
- The court held the controversy was a major dispute because Springfield’s conduct sought to change established work allocation and working conditions embodied in the agreement’s work-assignment clause.
- The court concluded Springfield’s use of ABR during mediation altered the status quo by diverting bargaining-unit work and was inconsistent with the carrier’s RLA obligations.
- The court held ABR could be enjoined because, on these facts, it functioned as the instrument through which Springfield attempted to circumvent statutory and contractual duties.
- The injunction was deemed appropriately tailored to maintain or restore the status quo pending completion of RLA procedures without deciding the merits of the underlying economic dispute.

## Legal Principles

- Under the RLA, a “major” dispute concerns attempts to change existing rates of pay, rules, or working conditions or to create new contractual rights; during such disputes, the parties must maintain the status quo while statutory procedures proceed.
- A carrier may not unilaterally reallocate bargaining-unit work covered by an existing agreement during RLA mediation; courts may issue status quo injunctions to prevent or reverse such changes.
- In applying the RLA’s status quo protections, courts may look beyond corporate form where a carrier uses a commonly controlled affiliate to evade RLA duties; a non-carrier entity may be bound by injunctive relief when necessary to prevent circumvention.
- Status quo injunctions should be limited to preserving existing conditions pending completion of the RLA process and should not impose new contract terms or resolve the substantive bargaining dispute.

## Conclusion

The First Circuit sustained an injunction preventing a commonly controlled non-carrier affiliate from performing switching work historically and contractually assigned to union employees, holding that the carrier’s diversion of work during RLA mediation constituted a major dispute and an impermissible change to the status quo.


Bhd. of Locomotive Eng’rs v. Springfield Terminal Ry. Co., 210 F.3d 18 (1st Cir. 2000)