The Fifth Circuit Court of Appeals has affirmed a lower court's dismissal of a retaliation lawsuit filed by a former American Airlines employee under the federal Railway Labor Act, dealing a setback to the worker's claims against the airline.

In *Reardon v. American Airlines, Incorporated* (5th Cir. 2026), the appeals court upheld the U.S. District Court for the Northern District of Texas's decision to dismiss Scott Reardon's case under Federal Rule of Civil Procedure 12(b)(1) for lack of subject-matter jurisdiction. The three-judge panel, consisting of Circuit Judges Barksdale, Willett, and Duncan, issued a per curiam opinion affirming the dismissal.

Reardon, who worked for American Airlines for 27 years, began his employment at Boston Logan Airport in 1996. He served as a facilities mechanic from 2003 until his termination in 2023. During the period relevant to his lawsuit, Reardon also held the position of union representative for the Transport Workers Union Local 591.

The case centered on Reardon's allegations of retaliatory termination under the Railway Labor Act, a federal statute that governs labor relations in the railroad and airline industries. The Railway Labor Act provides specific procedures for resolving labor disputes and protects workers from retaliation for union activities.

American Airlines and the Transport Workers Union Local 591 operate under a collective bargaining agreement that establishes wages, hours, and working conditions for union-represented employees. According to the court documents, the CBA includes provisions for "the prompt and equitable disposition of grievances" and "the establishment of fair wages, hours and working conditions."

The collective bargaining agreement also contains specific grievance and arbitration procedures that employees must follow when they believe they have been "unjustly dealt with" or when provisions of the agreement have not been "properly applied or interpreted." These procedures require employees to follow a series of escalating steps to resolve disputes.

The district court's dismissal under Rule 12(b)(1) indicates that the court determined it lacked the fundamental authority to hear Reardon's case. Subject-matter jurisdiction refers to a court's power to hear certain types of cases, and without it, a court cannot proceed to the merits of a dispute regardless of how strong a plaintiff's claims might be.

Jurisdictional dismissals in Railway Labor Act cases often arise from questions about whether employees have properly exhausted the grievance procedures required under their collective bargaining agreements before filing suit in federal court. The Railway Labor Act typically requires workers to pursue remedies through union grievance processes and arbitration before seeking relief in federal court.

The Fifth Circuit's affirmance suggests that Reardon failed to meet the jurisdictional requirements necessary to bring his case in federal court. While the brief per curiam opinion does not detail the specific reasoning behind the jurisdictional finding, such dismissals in Railway Labor Act cases frequently involve questions about procedural compliance with mandatory dispute resolution mechanisms.

This decision reflects the complex interplay between federal labor law and collective bargaining agreements in the airline industry. The Railway Labor Act's framework emphasizes alternative dispute resolution through union processes, which can create jurisdictional hurdles for employees seeking to pursue claims directly in federal court.

For American Airlines, the Fifth Circuit's affirmance represents a complete victory that avoids any examination of the underlying retaliation claims. The airline successfully defended against Reardon's lawsuit without having to address the merits of his allegations.

The case highlights the importance of procedural compliance in Railway Labor Act litigation. Employees in the airline industry who believe they have been subjected to retaliation must carefully navigate the grievance procedures established in their collective bargaining agreements before pursuing federal court remedies.

Reardon's loss at both the district court and appellate levels effectively ends his legal challenge unless he seeks review from the Supreme Court, though the high court rarely grants certiorari in Railway Labor Act cases that turn on jurisdictional questions.

The decision serves as a reminder to airline workers and their counsel about the critical importance of understanding and following the specific procedural requirements established under the Railway Labor Act and applicable collective bargaining agreements before filing federal lawsuits.

For the Transport Workers Union Local 591 and other airline worker unions, the case underscores the significance of their internal grievance and arbitration processes as the primary mechanism for resolving workplace disputes in the airline industry. The ruling reinforces the Railway Labor Act's emphasis on collective bargaining and alternative dispute resolution over federal court litigation.