Riki O’Hailpin; Nina Arizumi; Robert Espinosa; Erwin Young; Puanani Badiang; Sabrina Franks; Ronald Lum; Dan Saiki; Brandee Aukai v. Hawaiian Airlines, Inc.; Hawaiian Holdings, Inc.

Summary

This order addresses Hawaiian Airlines and Hawaiian Holdings’ motion to dismiss for lack of subject-matter jurisdiction under the Railway Labor Act. The court holds that Plaintiffs Riki O’Hailpin and Brandee Aukai’s Title VII religious-accommodation claims, and O’Hailpin’s ADA medical-accommodation claim, require interpretation of the applicable collective bargaining agreement and therefore constitute minor disputes subject to the Railway Labor Act’s dispute-resolution procedures. The claims are dismissed with prejudice for lack of subject-matter jurisdiction.

Holdings

1. The Railway Labor Act precludes court review of Plaintiffs’ Title VII and ADA failure-to-accommodate claims because determining the availability of the requested accommodations and the asserted undue-hardship defense requires interpretation of the existing collective bargaining agreement.
2. Jurisdictional discovery was not warranted because the jurisdictional issue was whether interpretation of the CBA was legally required, and additional discovery would not alter that determination.
3. Leave to amend was denied because Plaintiffs did not establish good cause to reopen the expired amendment deadline after nearly three years of litigation.

Questions Presented

1. Whether the Railway Labor Act deprived the district court of subject-matter jurisdiction over O’Hailpin’s and Aukai’s Title VII failure-to-accommodate claims and O’Hailpin’s ADA failure-to-accommodate claim because resolving them required interpretation of the parties’ collective bargaining agreement.
2. Whether Plaintiffs were entitled to jurisdictional discovery.
3. Whether Plaintiffs should receive leave to amend the complaint to add an intentional-discrimination claim.

Disposition

dismissed