Union Pacific R. Co. v. Locomotive Engineers and Trainmen Gen. Comm. of Adjustment, Central Region

Background

A railroad company disciplined five employees and the workers’ union filed grievances and asked the National Railroad Adjustment Board (NRAB) to arbitrate. The RLA asks parties to try to settle “in conference” before arbitration, but that conference can be informal. At the NRAB hearing, a panel member raised, on his own, that the on‑property record lacked written proof of conferencing. The panel dismissed all five cases as beyond its authority. The District Court affirmed; the Seventh Circuit reversed, and this Court agreed to review the issue.

Reasoning

The main question was whether written proof of an on‑property conference is a jurisdictional requirement that the NRAB must find before hearing a dispute. The Court held it is not. The justices explained that Congress alone defines the Board’s jurisdiction and that rules about how to present claims are usually claim‑processing rules that can be forfeited, not limits on the Board’s power to hear a case. The NRAB panel was wrong to treat the lack of documented conferencing as stripping the panel of jurisdiction, so the Board’s dismissals were invalid.

Real world impact

The decision lets employees seeking NRAB arbitration keep their claims alive even when conferencing was informal or not documented. NRAB panels can still set and enforce reasonable procedural rules, but they cannot redefine their statutory jurisdiction by elevating such rules to jurisdictional status. The Court did not decide broader questions about when courts may review Board procedures for due process; that issue remains for another case.