Cases & Deals

Spirit Airlines' successful motion to dismiss quickly affirmed by 11th Circuit

Clients Spirit Airlines, Inc.

The 11th Circuit affirmed Jones Day client Spirit Airlines Inc.'s successful motion to dismiss regarding their opening a new Operations Control Center (OCC) in Orlando, Florida. For operational reasons, Spirit decided to open the Orlando OCC in addition to its existing OCC at its headquarters in Miramar, Florida. It entered into voluntary discussions with the union representing its dispatchers (PAFCA) regarding the effects of that decision. After it was unable to reach agreement with PAFCA, Spirit announced it would proceed with the opening of Orlando. PAFCA sued to enjoin Spirit from doing so, arguing that the decision violated Spirit’s obligation under the Railway Labor Act to maintain the status quo. The district court granted Spirit’s motion to dismiss on the ground that Spirit was arguably justified under its collective bargaining agreement with PAFCA to open a second OCC, and thus, under the Supreme Court’s seminal Conrail decision, the dispute was “minor” and subject to exclusive and mandatory arbitration. PAFCA appealed, and the matter was argued to the 11th Circuit. Just seven days later, the 11th Circuit issued a decision affirming the district court’s decision and rejecting PAFCA’s efforts to distinguish the case from the Conrail line of cases.

The Professional Airline Flight Control Ass’n v. Spirit Airlines, Inc., Case No. 22-11341 (11th Cir.); The Professional Airline Flight Control Ass’n v. Spirit Airlines, Inc., Case No. 0:21-cv-60396-RKA (S.D. Fla.)