United Transportation Union v. Long Island Rail Road

Background

The case involves the Long Island Rail Road, a carrier that New York State acquired in 1966 and that provides both commuter and freight service, and the United Transportation Union representing its train crew employees. After collective bargaining in 1978 produced no agreement, federal mediation failed and the Union sued in December 1979 to declare that federal Railway Labor Act procedures, not New York’s Taylor Law for public employees, governed the dispute. The President intervened and imposed a 60-day cooling-off period. Days before that period expired, the State converted the railroad into a public benefit corporation hoping to avoid the federal law. A federal district court ruled for the Union, the Court of Appeals reversed, and the Supreme Court granted review.

Reasoning

The central question was whether applying the federal Railway Labor Act to a state-owned railroad would violate the Tenth Amendment by impairing traditional state functions. The Court applied the National League of Cities framework and focused on whether federal regulation would directly impair state sovereignty. It concluded railroad operation engaged in interstate commerce is not a traditional state function immune from federal regulation, emphasized a long history of federal oversight of railroads, and stressed Congress’s need for a uniform system to prevent disruptions to the national rail network. The Court also noted the State knowingly acquired and operated the railroad under federal rules for 13 years without claiming impairment.

Real world impact

The Court reversed the appeals court and held that the Railway Labor Act applies to the state-owned Long Island Rail Road. States cannot escape the federal railroad labor scheme simply by changing ownership, and employees on affected lines remain subject to federal bargaining procedures.