Does Section 4 of the Norris-LaGuardia Act prohibit the use of strike injunctions in cases arising under the RLA? Flight attendants employed by Transamerica Airlines, Inc., and represented by the Teamsters Union went on strike over new contract terms. The Air Line Pilots Association (ALPA), the exclusive bargaining representative of Transamerica's pilots, decided to honor Teamster picket lines, thereby grounding nearly all Transamerica's flights.

After a month of supporting the flight attendants, ALPA negotiated a back-to-workagreement with Transamerica and returned to work. The agreement included a clause stating, "There shall be no reprisals or recriminations by either side as a result of activities during the strike." After the pilots returned to work, ALPA initiated union disciplinary action against pilots who had flown during the strike, ultimately fining them the amount of money they earned during the strike.

The fined pilots refused to pay and brought an action in federal district court claiming ALPA violated the "no reprisal" clause of the back-to-work agreement by fining them. ALPA sought to dismiss the federal court action by contending that the federal court did not have jurisdiction under the RLA to decide matters of contract interpretation. Does the district court have jurisdiction? In which forum are contract interpretation disputes between ALPA and the carrierresolved?

[Frehtelkotter v. Air Line Pilots Association, 111 LRRM 3065 (9th Cir.)]