## Facts

- Airline mechanics originally employed by Eastern Airlines were represented by a machinists’ union.
- Eastern sold its shuttle operation to Trump Shuttle, and the shuttle mechanics transferred with the operation.
- In Eastern’s bankruptcy proceedings, the union previously asserted that the shuttle mechanics’ employment continued uninterrupted from Eastern to Trump Shuttle.
- The shuttle mechanics later decertified the union at Trump Shuttle and selected a different representative.
- Trump Shuttle was sold to US Airways, and the union again became the shuttle mechanics’ exclusive bargaining representative.
- US Airways integrated the shuttle mechanics into its main operations, requiring an agreement on seniority placement.
- During the US Airways integration, the union took the opposite position from the bankruptcy proceeding, asserting the shuttle mechanics had quit Eastern and been rehired by Trump Shuttle.
- The resulting seniority arrangement credited shuttle mechanics only from their Trump Shuttle start dates, reducing seniority-based benefits and leading to some furloughs.
- The mechanics alleged the union adopted this position to punish them for decertifying the union and for not joining a strike by main-operation mechanics (which shuttle mechanics could not participate in under their separate agreement).
- A jury found the union breached its duty of fair representation; the district court denied post-trial motions for judgment as a matter of law and for a new trial.

## Issues

1. Whether sufficient evidence supported the jury’s finding that the union breached its duty of fair representation by taking a hostile, retaliatory position in seniority integration.
2. Whether the district court should have granted judgment as a matter of law because no reasonable jury could find a breach.
3. Whether evidentiary rulings or jury instructions required a new trial.

## Decision

- The Second Circuit affirmed the judgment for the mechanics.
- The court held there was sufficient evidence for a reasonable jury to find the union acted discriminatorily or in bad faith by advocating a seniority position to disadvantage the shuttle mechanics.
- The court upheld the denial of judgment as a matter of law because the verdict was supported by record evidence permitting an inference of hostility.
- The court found no reversible error in the district court’s evidentiary rulings or jury instructions and affirmed the denial of a new trial.

## Legal Principles

- A union breaches the duty of fair representation only if its conduct is arbitrary, discriminatory, or in bad faith.
- In collective bargaining and seniority integration, unions receive substantial deference and have broad discretion to balance competing employee interests.
- “Arbitrary” conduct requires behavior outside the wide range of reasonableness, such that it is irrational given the circumstances at the time.
- Discriminatory or bad-faith conduct may be shown by evidence that union action was motivated by hostility or retaliatory animus toward a subgroup.
- Judgment as a matter of law is improper where record evidence allows a rational jury to find liability; appellate review is de novo for that denial and for abuse of discretion on denial of a new trial.

## Conclusion

The court upheld a jury finding that the union violated its duty of fair representation where evidence supported an inference that the union reversed its position on employment continuity and pressed a seniority rule to penalize a discrete group of mechanics for prior union-related choices, rather than for legitimate bargaining reasons.


Ramey v. District 141, Int’l Ass’n of Machinists & Aerospace Workers, 378 F.3d 269 (2d Cir. 2004)