Daniel George v. Piedmont Airlines

── Daniel George v. Piedmont Airlines ── Court: Court of Appeals for the Third Circuit Date: May 05, 2026 Category: General U.S. COURT OF APPEALS FOR THE THIRD CIRCUIT No. 25-1064 DANIEL GEORGE, Appellant v. PIEDMONT AIRLINES, INC. _____________________________ On Appeal from the U.S. District Court, E.D. Pa. Chief Judge Mitchell S. Goldberg, No. 2:23-cv-03939 Before: SHWARTZ, BIBAS, and PHIPPS, Circuit Judges Submitted: Mar. 3, 2026; Filed: May 5, 2026 _____________________________ NONPRECEDENTIAL OPINION* BIBAS, Circuit Judge. Some claims must be adjudicated out of court. Daniel George claims that his former employer, Piedmont Airlines, violated an anti-discrimination law. But because his claim depends on interpreting his collective-bargaining agreement, it must go to arbitration. So we will affirm the District Court’s dismissal. George was both a pilot for Piedmont Airlines and a Lieutenant Colonel in the U.S. Air Force Reserve. In the fall of 2019, he started a military leave of absence. Two years later, Piedmont and its pilots’ union added a new bonus program to their collective-bargaining agreement. Under that program, if a pilot was hired by American Airlines (Piedmont’s par- ent company) while still employed by Piedmont, he would get a $70,000 bonus in his last paycheck. * This is not an opinion of the full Court and, under 3d Cir. IOP 5.7, is not binding precedent.  While still on military leave, George interviewed with and got a job offer from Ameri- can. He told his Piedmont supervisor that he had the offer from American and planned to leave Piedmont; at first, his supervisor responded that he should get the bonus automati- cally. So George told Piedmont that he would resign in three weeks to start the new job. But the next day, his supervisor called back to say that his resignation would become effec- tive immediately. Soon after, another Piedmont employee said he would not get the bonus. George and his union filed a grievance under the collective-bargaining agreement, chal- lenging Piedmont’s denying him the bonus. Yet the arbitration panel rejected that griev- ance, reasoning that when American hired George, he was no longer a Piedmont employee. Then George filed this lawsuit, alleging that Piedmont had violated the Uniformed Ser- vices Employment and Reemployment Rights Act of 1994 (USERRA) by denying him the bonus because of his military service. The District Court dismissed for lack of subject- matter jurisdiction, concluding that the Railway Labor Act required arbitrating his claim. George v. Piedmont Airlines, Inc., 761 F. Supp. 3d 804, 807 (E.D. Pa. 2025). Reviewing de novo, we conclude that the Railway Labor Act does indeed prevent us from deciding the merits of George’s claim. Stouffer v. Union R.R., 85 F.4th 139, 143 (3d Cir. 2023). Under the Railway Labor Act, “minor disputes” between labor and management in rail- roads and airlines must go to arbitration. Id. at 144. Minor disputes are ones involving rights created or defined by the parties’ collective-bargaining agreement. When a claim “depends for its resolution on the interpretation of a CBA,” the Railway Labor Act pre- cludes bringing suit on that claim. Id. (internal quotation marks omitted). A claim depends on interpreting the agreement when it “may be conclusively resolved by” that 2 interpretation. Id. (internal quotation marks omitted). By contrast, “purely factual ques- tions” about an employer’s or employee’s actions or motives do not require interpreting the agreement. Id. at 144–45 (internal quotation marks omitted). Claims raising such questions can normal