District Court Finds ERISA Claim Preempted by the Railway Labor Act in Pilot’s Long-Term Disability Case

In Eldredge v. Am. Airlines Inc., No. CV-25-00823-PHX-SMB, 2025 WL 2549405 (D. Ariz. Sept. 4, 2025), the District Court for the District of Arizona dismissed a pilot’s ERISA claim for long-term disability (LTD) benefits, holding that the dispute was a “minor dispute” under the Railway Labor Act (RLA) and therefore outside the court’s jurisdiction. The decision highlights the complex intersection of ERISA rights and collective bargaining agreements (CBAs) in the airline industry.

Plaintiff Eldredge was a pilot for American Airlines and a member of the Allied Pilots Association (APA). His employment was governed by a Joint Collective Bargaining Agreement (JCBA) between the airline and the union. After being diagnosed with substance use disorder, Eldredge applied for long-term disability benefits under American Airlines’ LTD plan. The plan was subject to ERISA.

American Airlines denied his claim, arguing he was not an “employee” at the time of his disability and that the condition stemmed from criminal activity. Eldredge appealed twice, but both appeals were denied, the final denial coming from the company’s Employee Benefits Committee. That decision informed him he could bring a civil action under ERISA § 502(a). Eldredge then filed suit in federal court, alleging wrongful denial of benefits under ERISA.

American Airlines moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), asserting that the Railway Labor Act vested exclusive jurisdiction over the claim in a System Board of Adjustment (SBA), not the courts.

The Legal Framework

Federal courts normally have jurisdiction over ERISA claims under 28 U.S.C. § 1331. However, the RLA provides that disputes growing out of grievances or the “interpretation or application” of CBAs—called “minor disputes”—must be resolved through arbitration before an SBA, not in court. Courts must therefore ask whether a claim arises independently under ERISA or is instead grounded in the CBA.

The Ninth Circuit applies a two-step test:

1. Does the claim seek to vindicate a right created by the CBA itself?
2. If not, does resolution of the claim require interpretation or application of the CBA?

If either applies, the claim is preempted as a minor dispute under the RLA.

The Court’s Analysis

American Airlines argued that Eldredge’s claim was a minor dispute because the LTD plan was established and maintained pursuant to the JCBA. Specifically, “Letter KK(2)” of the JCBA obligated the airline to provide the LTD plan, set material terms such as benefit amounts and duration, and required amendments and administration to be handled jointly with the APA. The JCBA also provided that any disputes would be resolved through grievance and arbitration procedures.

Eldredge countered that his claim arose under ERISA, not the JCBA. He emphasized that the plan itself stated that “neither the interpretation of the Plan nor its administration shall…be within the jurisdiction of the JCBA” and even provided participants with the right to file suit in federal court if claims were denied. He argued that American Airlines’ reliance on the JCBA was misplaced.

The court sided with American Airlines. Relying heavily on Pearson v. Northwest Airlines, Inc., 659 F. Supp. 2d 1084 (C.D. Cal. 2009), the court found the LTD plan was “inextricably intertwined” with the JCBA. While ERISA creates a right to bring claims for benefits, Eldredge’s alleged right to LTD benefits existed only because the JCBA required the airline to provide the plan. Thus, the JCBA was the true source of the claim.

The court rejected Eldredge’s reliance on Bonin v. American Airlines, Inc., 621 F.2d 635 (5th Cir. 1980). In Bonin, the court retained jurisdiction because the pension plan at issue was not created pursuant to a CBA. By contrast, American’s LTD plan was expressly established and controlled through the JCBA. Even though the plan contained language suggesting claimants could sue in federal court, that provision could not override the statutory mandate of the RLA when the plan was grounded in the collective bargaining process.

Conclusion

The court concluded that Eldredge’s ERISA claim was a “minor dispute” under the RLA and thus subject to arbitration before the SBA, not federal court review. Accordingly, it granted American Airlines’ motion to dismiss and directed entry of judgment in the airline’s favor. Eldredge was denied leave to amend because no additional facts could cure the jurisdictional defect.

This case underscores the difficulties employees face when seeking ERISA remedies in industries governed by the RLA. While ERISA generally provides a federal forum for benefit disputes, where a plan is created and maintained pursuant to a CBA, claims may be channeled into the RLA’s arbitration system instead. For airline and railroad employees, the boundary between ERISA and the RLA remains fraught, with courts often agreeing with employers in finding preemption.

For pilots and unionized employees, this means that even if a plan document suggests federal court remedies, the ultimate question will be whether the benefit rights truly arise from the CBA. If so, disputes are likely to be classified as “minor disputes” requiring arbitration, not litigation.