This Comment argues that Williams v. Jacksonville Terminal Co. either should be overruled, or should be appropriately limited to the fact-specific setting under which it was decided. To develop this thesis, Part II of this Comment will discuss both the history of labor unrest which drove Congress to pass the RLA and the design features of the RLA legislation which facilitate an atmosphere of cooperative bargaining through which the RLA dispute resolution system operates. Part III will discuss the first impression Williams case, wherein the Supreme Court gave an overly restrictive interpretation to the RLA, and will also discuss the post-Williams treatment of new unions under the RLA. Part IV will discuss a recent Second Circuit case, Aircraft Mechanics Fraternal Ass'n v. Atlantic Coast Airlines, Inc., in order to illustrate how continued adherence to Williams' restrictive interpretation of the RLA defeats the intent of Congress. Part V will present proposals to rectify the unfortunate implications for labor peace resulting from the Williams Court's misinterpretation of the RLA. The Comment concludes by reinforcing the fact that the RLA was intended to prevent labor strife, and continued adherence to the Williams decision will only lead to increased labor strife.
Mark A. Schuler, The Railway Labor Act of 1926 and Modern-Day Airline Labor Strife: Progress Toward Labor Peace Begins With Overruling Williams v. Jacksonville Terminal Co., 21 SEATTLE U. L. REV. 189 (1997).