FEDERALCourt of Appeals for the Ninth Circuit
1990

Barthelemy v. Air Lines Pilots Ass'n

897 F.2d 999Court of Appeals for the Ninth Circuit • Decided 1990Enforced
FLAGSHIPDispute ResolutionChange OrderCited 156 times

HOLDING

Two pilots sued their union (ALPA) for negotiating pay cuts with a corporate takeover bidder without their consent. The Ninth Circuit ruled that unions have broad discretion to negotiate on behalf of members during corporate changes, even if individual members disagree. The court upheld the agreement because the union acted in good faith to protect pilot interests. For subcontractors, this means unions and contractors can negotiate protective agreements during ownership changes without needing approval from every individual member.

KEY FINDINGS

Dispute Resolution

Unions can negotiate directly with prospective owners during takeovers if they believe it protects member interests—individual members cannot block these deals just because they disagree

Change Order

Good faith negotiations during corporate transitions are protected, even if terms are unfavorable to some workers

FULL COURT OPINION