Federal Express Corp vs California Public Utilities Commission, 9th Circuit Court of Appeals, 1991:
The trucking operations of Federal Express are integral to its operation as an air carrier. The trucking operations are not some separate business venture; they are part and parcel of the air delivery system. Every truck carries packages that are in interstate commerce by air. The use of the trucks depends on the conditions of air delivery. The timing of the trucks is meshed with the schedules of the planes.
If you want to bring some of your other silly "COURIERS DON'T FLY PLANES THEY DRIVE TRUCKS!!' gibberish into the discussion...
United Parcel Service, Inc. vs NLRB, United States Court of Appeals, 1996:
Moreover, the NMB has typically required a trucking service that is commonly owned and operated with an RLA carrier to meet at least three criteria before the NMB would consider exercising jurisdiction over the service:
1:the trucker must perform services principally for an RLA carrier with which it is affiliated;
2:the trucker must be an integral part of that affiliate; and
3:the trucker must provide services "essential to the [RLA] carrier's operations."
And while we're at it...
Federal Express Corporation, NMB File No. CJ-6463, NLRB Case 4-RC-17698, 23 NMB No. 13 (Nov. 22, 1995):
The RLA does not limit its coverage to air carrier employees who fly or maintain aircraft. Rather, its coverage extends to virtually all employees engaged in performing a service for the carrier so that the carrier may transport passengers or freight. ... The limit [on coverage] is that the carrier must have continuing authority to supervise and direct [its employees]. ... The couriers, tractor-trailer drivers, operations agents and other employees sought by the UAW are employed by FedEx directly. As the record amply demonstrates, these employees, as part of FedEx’s air express delivery system, are supervised by FedEx employees. The Board need not look further to find that all of the FedEx [Express] employees are subject to the RLA. ...
It has been the Board’s consistent position that the fact of employment by a “carrier” under the Act is determinative of the status of all that carrier’s employees as subject to the Act. The effort to carve out or to separate the so-called over-the-road drivers would be contrary to and do violence to a long line of decisions by this Board which would embrace the policy of refraining from setting up a multiplicity of crafts or classes.
Oh, and there's this...
Federal Express Corporation, NMB File No. CJ-6463, NLRB Case 4-RC-17698), 23 NMB No. 13, at 73–74 (Nov. 22, 1995):
Where, as here, the company at issue is a common carrier by air, the Act’s jurisdiction does not depend upon whether there is an integral relationship between its air carrier activities and the functions performed by the carrier’s employees in question. The Board need not consider the relationship between the work performed by employees of a common carrier and the air carrier’s mission, because [the RLA] encompasses every pilot or other person who performs any work as an employee or subordinate official of such carrier or carriers. ...
Even if the Board were to assume, arguendo that the “integrally related” test applies to the facts in this case, the Board would hold in concurrence with the [FedEx v. California PUC decision] that the trucking operations of FedEx [Express] are integral to its operations as an air carrier.
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