[co-author: Justin Stucki]*
Seyfarth Synopsis: The Northern District of California recently issued two rulings with noteworthy employment implications for commercial air carriers. The first ruling represents the first time a court has found that federal aviation safety regulations preempted California-based pilots’ meal and rest period claims based on the California Labor Code. The district court also ruled that the air carrier was not required to reimburse pilots for their alleged work-related use of personal cell phones when company phones were provided. Meanwhile, a different district court rejected the argument that pilots are exempt from California state wage-hour laws under the “learned professionals” exception. Horowitz v. SkyWest Airlines, Inc. and Goldthorpe, et al. v. Cathay Pacific Airways Ltd.
A Win for SkyWest Airlines Against Putative Class of California-Based Pilots
In Horowitz v. SkyWest Airlines, Inc., the district court granted SkyWest’s motion for summary judgment on the grounds that the Federal Aviation Act (FAAct) preempted California wage-hour claims brought on behalf of SkyWest’s California-based pilots. Plaintiff alleged that SkyWest failed to provide California-based pilots with the meal and rest periods to which they believed they were entitled. But, for the first time, the district court ruled that the FAAct, and accompanying regulations, preempt such claims under California law.
The district court relied on the Ninth Circuit case Ventress v....
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