Supreme Court
Boeing Co., v. Sw. Airlines Pilots Ass’n
- Case number: 22-0631
- Legal category: Federal Preemption
- Subtype: Railway Labor Act
- Set for oral argument: March 19, 2025
Case Summary
This case raises questions of federal preemption and the assignability of causes of action.
In 2016, the Southwest Airlines Pilots Association entered a collective bargaining agreement with the airline on behalf of its member pilots and agreed that the pilots would fly the new Boeing 737 MAX aircraft. The FAA grounded the aircraft in 2019, and SWAPA sued Boeing in state court on behalf of itself and its pilots for the resulting damages. Boeing removed the case to federal court, but that court determined it lacked jurisdiction and remanded. While the remand motion was pending, over 8,000 pilots assigned all grounding-related claims against Boeing to SWAPA. Boeing filed a plea to the jurisdiction following the remand, arguing that SWAPA lacked standing to bring claims on behalf of the pilots and that the Railway Labor Act preempted SWAPA’s own state law claims. The trial court granted the plea and dismissed both sets of claims with prejudice.
The court of appeals reversed in part and modified the trial court’s judgment in part. It held that SWAPA did not meet the associational standing requirements to bring claims on behalf of its pilots. But the court recognized that the pilots’ assignment of their claims could confer standing on SWAPA in a future suit and modified the trial court’s dismissal as to those claims to be without prejudice. It then held that SWAPA possessed standing to bring claims on its own behalf and reversed the trial court’s dismissal of those claims. Finally, the court held that SWAPA’s own claims were not preempted by the Act because it only preempts claims between airline carriers and employees.
Boeing petitioned for review. It argues that the Act preempts all claims requiring the interpretation of a collective bargaining agreement and not just those involving airline carriers and employees. Boeing also argues that the pilots’ assignments could not confer future standing on SWAPA because they circumvent associational standing limitations and should be invalidated on public policy grounds. The Supreme Court granted Boeing’s motion for rehearing and its petition for review.
Case summaries are created by the Court's staff attorneys and law clerks and do not constitute the Court’s official descriptions or statements. Readers are encouraged to review the Court’s official opinions for specifics regarding each case.