## Facts

- Grant T. Norris, an FAA-licensed mechanic employed by Hawaiian Airlines, worked under a collective-bargaining agreement (CBA) governing duties including aircraft inspection and certification for return to service.
- During a preflight inspection, Norris found a landing-gear component (an axle sleeve) scarred and grooved and recommended replacement due to safety risk.
- A supervisor directed that the sleeve be sanded and reused, and the aircraft flew as scheduled.
- Norris refused to sign the maintenance record certifying the repair and airworthiness, as required by federal regulations and referenced by the CBA.
- The airline suspended Norris immediately and later terminated him for insubordination.
- Norris reported the incident to the FAA; the FAA investigated and pursued enforcement action that later ended in a settlement including a fine against the airline.
- Norris pursued the CBA grievance process but was unsuccessful, then filed state-court actions alleging wrongful discharge in violation of public policy reflected in federal aviation safety law and under Hawaii’s whistleblower statute.

## Issues

1. Whether the Railway Labor Act (RLA) preempts state-law wrongful discharge and whistleblower claims when the employee is covered by a CBA.
2. Whether such claims are “minor disputes” subject to the RLA’s exclusive arbitral mechanism because the employer may invoke CBA provisions as a defense.
3. Whether a state claim is preempted when resolving it may require consulting, but not construing, the CBA.

## Decision

- The Supreme Court affirmed the judgment allowing Norris’s state-law claims to proceed.
- The Court held that the RLA does not preempt state-law causes of action that enforce rights and duties existing independently of a CBA.
- Norris’s claims turned on factual questions about the employer’s reasons for discharge and alleged retaliation for refusing to certify unsafe work and for reporting safety concerns, not on interpretation of CBA terms.
- The Court rejected the view that a claim becomes a “minor dispute” merely because the CBA is relevant or because a contractual remedy could also be pursued.

## Legal Principles

- RLA “minor disputes” are limited to disputes grounded in a CBA that require interpretation or application of the agreement.
- A state-law cause of action is not preempted if it involves rights and obligations that exist independent of the CBA.
- The RLA preemption inquiry tracks the approach used for LMRA § 301: preemption applies only when resolving the state claim depends on construing the CBA, not when the CBA provides background or a parallel contractual claim.
- “Purely factual” determinations about conduct and motive may be resolved without interpreting CBA terms; such claims remain within state judicial authority.

## Conclusion

The Court held that the RLA’s arbitral scheme does not displace state wrongful discharge and whistleblower claims rooted in independent statutory or public-policy rights, even when the employment relationship is governed by a CBA, so long as adjudication does not require interpreting the agreement.


Hawaiian Airlines, Inc. v. Norris, 512 U.S. 246 (1994)