Whistleblower Digest

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Whistleblower Digest

Aviation Investment and Reform Act for the 21st

Century (AIR21)

Last updated July 1, 2021

Table of Contents

I.

STATUTE AND REGULATIONS .................................................................................................... 4

•

Final AIR21 Regulations .................................................................................................................... 4

•

Consolidated Appropriations Act of 2021 ......................................................................................... 4

II.

JURISDICTION ............................................................................................................................. 5

•

Extraterritoriality .............................................................................................................................. 5

•

Authority of ALJ and ARB to invalidate employer policy ................................................................. 11

•

Employer’s interests and protection of pilots ................................................................................. 11

III.

BURDEN OF PROOF AND PRODUCTION ............................................................................ 13

•

Prima facie case .............................................................................................................................. 13

•

ALJ errors in analytical framework or credibility determinations ................................................... 14

•

Burdens of proof in AIR21 whistleblower complaint; general outline ............................................ 14

•

Applicable decisional law; burdens of proof and production .......................................................... 15

IV.

PROTECTED ACTIVITY ........................................................................................................... 16

•

In general ........................................................................................................................................ 16

V.

ADVERSE EMPLOYMENT ACTION .......................................................................................... 48

•

Hostile work environment ............................................................................................................... 49

•

Suspension without pay .................................................................................................................. 51

•

Discipline and constructive discharge ............................................................................................. 52

•

“Check ride” tests ............................................................................................................................ 54

•

Voluntary resignation or employer termination ............................................................................. 56

•

Materially adverse standard ........................................................................................................... 58

VI.

CAUSATION / CONTRIBUTING FACTOR ............................................................................ 69

•

Contributing factor generally; Palmer’s Two Step Burden of Proof ................................................ 75

•

Respondent’s knowledge of protected activity ............................................................................... 95

•

Pretext ............................................................................................................................................. 96

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VII.

AFFIRMATIVE DEFENSE / CLEAR AND CONVINCING EVIDENCE STANDARD ... 101

VIII.

TIMELINESS OF COMPLAINT ......................................................................................... 116

•

Ninety-day limitation .................................................................................................................... 116

•

Equitable tolling ............................................................................................................................ 117

•

Continuing violation doctrine inapplicable ................................................................................... 127

•

Blacklisting .................................................................................................................................... 128

•

Timeliness of hearing request ....................................................................................................... 128

•

Request for formal hearing ........................................................................................................... 130

IX.

PROCEDURE BEFORE OALJ ................................................................................................ 130

•

Amendment of complaint ............................................................................................................. 130

•

Findings on complaint still before OSHA ....................................................................................... 131

•

Recusal of ALJ ................................................................................................................................ 132

•

Summary decision ......................................................................................................................... 133

•

Self-represented litigants....................................................................................................... 133

•

Weighing evidence................................................................................................................ 136

•

Relevancy .............................................................................................................................. 137

•

Motion to Dismiss ......................................................................................................................... 138

•

Due process ................................................................................................................................... 139

•

Remands........................................................................................................................................ 140

X.

•

ALJ reassignment.................................................................................................................. 140

•

New hearing .......................................................................................................................... 141

•

Inadequacy of complaint ....................................................................................................... 141

•

Different service methods for ALJ and opposing party ........................................................ 142

ARB REVIEW ................................................................................................................................ 142

•

Scope of review ............................................................................................................................. 142

•

Ability of ALJ to correct mistakes in appealed decisions ............................................................... 144

•

Pro se complainants ...................................................................................................................... 145

•

Interlocutory Review ..................................................................................................................... 145

XI.

SUBPOENAS............................................................................................................................... 149

XII.

PROCEDURE BEFORE ARB .................................................................................................. 152

•

Timeliness of request for ARB review ............................................................................................ 152

•

Petition for review ......................................................................................................................... 156

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•

Briefing .......................................................................................................................................... 157

•

Exceptional circumstances: interlocutory review of ALJ decision ................................................. 158

•

Record not before ALJ ................................................................................................................... 159

•

Issues on appeal ............................................................................................................................ 160

•

New arguments on appeal ............................................................................................................ 161

•

Reconsideration of ARB decision ................................................................................................... 162

•

Jurisdiction of federal courts ......................................................................................................... 163

•

Standard of review ........................................................................................................................ 165

•

Attorney’s fees .............................................................................................................................. 165

XIII.

PROCEDURE BEFORE THE FEDERAL COURTS ......................................................... 166

•

Federal district court jurisdiction .................................................................................................. 166

•

Possible preclusive effect of ALJ’s factual findings ........................................................................ 168

•

Compelling arbitration .................................................................................................................. 169

XIV.

EMPLOYER / EMPLOYEE / OTHERS .............................................................................. 169

•

Amendment of 49 U.S.C. § 42121 ................................................................................................. 169

•

Covered employers ........................................................................................................................ 170

•

Covered employees ....................................................................................................................... 174

•

Others ............................................................................................................................................ 178

XV.

EVIDENCE ................................................................................................................................. 178

XVI.

DAMAGES .............................................................................................................................. 183

XVII.

REINSTATEMENT AND EQUITABLE REMEDIES ....................................................... 193

XVIII.

ATTORNEY'S FEES AND COSTS ...................................................................................... 198

XIX.

DISMISSALS .......................................................................................................................... 207

•

Dismissal for cause before ALJ ...................................................................................................... 207

•

Dismissal for failure to state a claim upon which relief can be granted ....................................... 210

•

Stipulated dismissal....................................................................................................................... 211

•

Dismissal for cause before the ARB ............................................................................................... 211

XX.

MISCONDUCT AND SANCTIONS ......................................................................................... 212

XXI.

DELIBERATE VIOLATION ................................................................................................ 215

XXII.

SETTLEMENTS ..................................................................................................................... 215

XXIII.

RES JUDICATA ..................................................................................................................... 216

XXIV.

RELATIONSHIP TO OTHER LAWS/FORUM ................................................................. 216

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•

Federal Arbitration Act .................................................................................................................. 216

•

State laws ...................................................................................................................................... 224

•

United States Constitution ............................................................................................................ 226

XXV.

BANKRUPTCY ...................................................................................................................... 227

I.

STATUTE AND REGULATIONS

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (AIR21)

was signed into law on April 5, 2000. The Act includes a whistleblower protection provision found

at 49 U.S.C. 42121.

•

Final AIR21 Regulations

On March 21, 2003, the Occupational Safety and Health Administration published a Final

Rule implementing the whistleblower provision of AIR21. Procedures for the Handling of

Discrimination Complaints Under Section 519 of the Wendell H. Ford Aviation Investment and

Reform Act for the 21st Century, Final Rule, 68 Fed. Reg. 14099 (Mar. 21, 2003). Among the

changes found in the Final Rule are (1) clarifications in the definitions section, (2) a clarification

of the complainant's burden of proof, (3) a change to lengthen the time provided for a respondent

to file a response with OSHA, (4) a clarification that an order of reinstatement is not appropriate

when it is established that the complainant is a security risk (whether or not the information is

obtained after the complainant's discharge), (5) a clarification that a respondent may seek

attorneys’ fees incurred during the OSHA investigation (up to $1,000) in a hearing before an ALJ

if it alleges that the complaint was frivolous or brought in bad faith, and (6) a provision that appeals

to the ARB are not a matter of right, but accepted at the discretion of the ARB.

•

Consolidated Appropriations Act of 2021

AIR21 was amended by the Consolidated Appropriations Act, 2021, H.R. 133, Section 118

of the Aircraft Certification, Safety, and Accountability Act. The Consolidated Appropriations

Act expanded coverage from air carriers and their contractors and subcontractors to holders of

certificates and their contractors, subcontractors, and suppliers. A summary of changes is below.

49 U.S.C. 42121(a)

Old language: “Discrimination against airline employees. No air carrier or contractor

or subcontractor of an air carrier may discharge an employee or otherwise discriminate

against an employee . . .”

New language: “Prohibited discrimination. A holder of a certificate under section

44704 or 44705 of this title, or a contractor, subcontractor, or supplier of such holder,

may not discharge an employee or otherwise discriminate against an employee . . .”

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49 U.S.C. 42121(d)

Old language: “Subsection (a) shall not apply with respect to an employee of an air

carrier, contractor, or subcontractor who, acting without direction from such air carrier,

contractor, or subcontractor (or such person’s agent), deliberately causes a violation of any

requirement relating to air carrier safety under this subtitle or any other law of the United

States.”

New language: “Subsection (a) shall not apply with respect to an employee of a holder

of a certificate issued under section 44704 or 44705, or a contractor or a subcontractor

thereof, who, acting without direction from such certificate-holder, contractor, or

subcontractor (or such person’s agent), deliberately casues a violation of any requirement

relating to aviation safety under this subtitle or any other law of the United States.”

49 U.S.C. 42121(e)

Old language: “In this section, the term “contractor” means a company that performs

safety-sensitive functions by contract for an air carrier.

New language: “In this section, the term ‘contractor’ means –

(1) a person that performs safety-sensitive functions by contract for an

air carrier or commercial operator; or

(2) a person that performs safety-sensitive functions related to the

design or production of an aircraft, aircraft engine, propeller,

appliance, or component therof by contract for a holder of a certificate

issued under section 44704.

II.

JURISDICTION

•

Extraterritoriality

AIR21 DOES NOT APPLY EXTRATERRITORIALLY; KEY FACTOR FOR DECIDING

WHETHER A CLAIM IS DOMESTIC OR EXTRATERRITORIAL IN APPLICATION IS

THE LOCATION OF THE EMPLOYEE’S PERMANENT OR PRINCIPAL WORKSITE

In Shi v. Moog Inc., ARB No. 2017-0072, ALJ No. 2016-AIR-00020 (ARB Dec. 5, 2019) (per

curiam), the ALJ dismissed Complainant’s AIR21 complaint because its adjudication would

require impermissible extraterritorial reach. On appeal, the ARB looked to the Supreme Court’s

decision in Morrison v. Nat’l Australia Bank, Ltd., 561 U.S. 247 (2010) and the ARB’s SOX

decision applying Morrison in Hu v. PTC Inc., ARB No. 2017-0068, ALJ No. 2017-SOX-00019

(ARB Sept. 18, 2019). The ARB noted that the Morrison analysis has two steps: “(1) whether the

statute at issue extends extraterritorially and, if not, (2) whether the activity comprising the focus

of the statute occurred within the United States or outside of it.” Slip op. at 3 (citations omitted).

The ARB further noted: “If the activity identified under Step 2 occurred within the U.S., then there

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is a permissible domestic application of the statute. . . . lf the activity occurred outside the U.S.,

then there is an impermissible extraterritorial application and the complaint must be dismissed.”

Id. at 3-4 (citations omitted).

The ARB reviewed the text of AIR21 and determined that “the employee protection provisions of

AIR 21 are not extraterritorial.” Id. at 4. The ARB thus ruled that “to allow the adjudication of the

complaint before us, it must be a domestic application of the employee protection provision of

AIR 21.” Id. The ARB determined that, although the overarching purpose of AIR21 may be air

carrier safety, the primary focus of the employee protection provisions of AIR21 “are necessarily

connected to the employee's compensation, terms, conditions, or privileges of employment.” Id. at

5. Accordingly, the ARB determined that the key factor for deciding whether a claim is domestic

or extraterritorial in application is the location of the employee’s permanent or principal

worksite—and that the location of other conduct is less critical, if not irrelevant. The ARB stated:

[A]n AIR 21 complaint concerning an adverse action that affects an employee at a

foreign principal worksite does not become territorial because the alleged

misconduct occurred in the U.S., or because it had, or would have, effects on U.S.

air carrier safety, or because the alleged retaliatory decision was made in the U.S.

Id. In the instant case, it was undisputed that:

. . . Complainant's primary worksite was in China, he was employed under a

Chinese contract, he was paid in Chinese currency, and his direct employer was a

Chinese corporation. The only alleged domestic contacts in this matter are that

Complainant 1) took a few work-related trips to the U.S., 2) believes that some of

the people responsible for the adverse action taken against him may be U.S.

citizens, and 3) complained about counterfeit parts that were used to manufacture

aircraft in the U.S. which were flown in the U.S.

Id. The ARB stated that such allegations, even if true, would not by themselves create a domestic

application of AIR21. The ARB thus affirmed the ALJ’s dismissal of the complaint.

The ARB noted that the FAA, which has primary responsibility for protecting aviation safety, had

been notified of and had investigated the matter.

EXTRATERRITORIAL APPLICATION OF AIR21 WHISTLEBLOWER PROVISION;

DISTRICT COURT DISMISSED RESPONDENT’S REQUEST FOR DECLARATORY

AND INJUNCTIVE RELIEF FROM DOL PROCEEDING ON THEORY THAT THE

ADMINISTRATIVE ADJUDICATION OVER A FOREIGN COMPANY WAS ULTRA

VIRES; RATHER THE AIR21 STATUTORY REVIEW SCHEME ALLOWS A

RESPONDENT TO SEEK REVIEW OF AN ADVERSE FINAL DOL ORDER BEFORE A

U.S. COURT OF APPEALS

In Bombardier, Inc. v. USDOL, 145 F. Supp. 3d 21 (D.D.C. Nov. 12, 2015) (case below 2014AIR-00017), the Plaintiff, a Canadian company that designs and manufactures aircraft and which

does not provide air transportation to the public, sought declaratory and injunctive relief on the

ground that DOL acted ultra vires by exercising jurisdiction over it in an impermissible

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extraterritorial application of the AIR21 whistleblower protection provision. The complainant in

the administrative action alleged that the Plaintiff discriminated against him by terminating his

employment in retaliation for reporting safety of flight issues on an aircraft that had been flight

tested in Wichita, Kansas. OSHA had dismissed for lack of jurisdiction, finding that the Plaintiff

was not an air carrier, the complainant was not an employee, within the meaning of the applicable

provisions of AIR21. Before the ALJ, the complainant argued that the Plaintiff was covered as an

air carrier, or contractor of an air carrier, for AIR21 purposes, and that he was thus an employee

under AIR21. The Chief ALJ issued an order to show cause why the complaint should not be

dismissed for lack of jurisdiction, but ultimately declined to dismiss because the complainant met

the “fair notice” minimal pleading requirements for a DOL whistleblower protection proceeding.

The case was then assigned to a presiding ALJ who denied the Plaintiff’s (i.e., Bombardier) motion

for summary decision, finding that the record showed a significant nexus between the Plaintiff and

the U.S. The ALJ denied the Plaintiff’s request for leave to file an interlocutory appeal to the ARB,

request to stay discovery, and alternative request for the ALJ to reconsider the denial of summary

decision. The ALJ also affirmed the earlier denial of summary decision, noting that the standard

for consideration of such a motion required viewing the evidence in the light most favorable to the

complainant. As the Plaintiff continued to resist the administrative proceedings, it filed the district

court action. The ALJ had not yet held a hearing on the merits.

Statutory review scheme

DOL argued before the district court that (1) the Plaintiff failed to exhaust its administrative

remedies, and (2) “the existing administrative scheme, which allows Bombardier to seek review

of a final Department order in a United States Court of Appeals, precludes review by a district

court now.” Slip op. at 13. The district court found the second argument persuasive and thus did

not address the exhaustion argument. The court first examined the statutory scheme’s text,

structure and purpose and found that it has “much in common with other review schemes that

preclude premature district court review.” Id. at 15. The court found that the AIR21 whistleblower

review scheme “carries a fairly discernible congressional intent to preclude extrastatutory district

court suits.” Id. at 19 (footnote omitted). The court then examined whether the complainant’s

AIR21 claims are of the type Congress intended to be reviewed within the statutory structure. The

court found that the Plaintiff did not lack meaningful administrative review of its claims, noting

that DOL had adjudicated its jurisdictional challenge and that the jurisdictional issue was an open

issue that, if found adversely to the Plaintiff’s position, could be appealed to a court of appeals.

The court found that the burden of discovery was not constitute irreparable injury. The Plaintiff’s

objection that the U.S. government’s administrative process is “out of line” merely highlights what

that process is trying to determine: whether the Plaintiff’s actions fall under U.S. regulatory

authority. The court noted that the Plaintiff might, after a hearing on merits, convince the ALJ that

AIR21 could not apply to the Plaintiff – or the ARB could rule in the Plaintiff’s favor on review

of the ALJ’s decision. The court stated:

Bombardier’s situation shows us precisely why courts tend to “await the

termination of agency proceedings:” so that the agency proceedings may “obviate

all occasion for judicial review.” Jarkesy v. SEC, 803 F.3d 9, 27 (D.C. Cir. 2015)

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(quoting Standard Oil, 449 U.S. at 244 n.11). This is “a feature” of the

administrative process, “not a bug.” Id.

Id. at 28. The court was not persuaded that its claims were wholly collateral to the AIR21 review

provisions, or that the claims were outside DOL’s expertise. The court summarized:

In sum, Bombardier’s claims are of the type intended to be reviewed within the

AIR21 statutory structure. Pursuing these claims administratively will not foreclose

later meaningful judicial review, the claims are not wholly collateral to AIR21

review provisions, and those claims do not fall outside the Department’s expertise.

For these reasons, and because the AIR21 statutory structure has a fairly discernible

intent to preclude premature suits in federal court, Bombardier’s complaint must be

dismissed. Holding otherwise would continue the parallel litigation of identical

issues in this Court and in the Department of Labor, leaving open the possibility of

future inconsistent judgments. See generally Jarkesy v. SEC, 803 F.3d 9, 30 (D.C.

Cir. 2015) (discussing this possibility). To avoid that unwelcome result, the Court

will dismiss Bombardier’s complaint for lack of jurisdiction.

Id. at 33 (footnote omitted).

Administrative Procedure Act

The court was no more persuaded by the Plaintiff’s APA claim, noting that the APA’s review

provisions are not jurisdictional. The court noted that “[e]xisting statutory review procedures are

adequate when they offer relief of the “same genre” as APA review” . . . and that here, once the

Plaintiff “obtains a final order from the Department, AIR21 grants it the right to judicial review in

a court of appeals and specifies that appellate review must conform to the APA. See 49 U.S.C. §

42121(b)(4)(A) . . . .” Slip op. at 38 (citations omitted). The court summarized:

In other words, AIR21’s statutory review procedures do not just offer relief of the

“same genre” as APA review; judicial review under AIR21 exactly parallels review

otherwise available under the APA. Because the AIR21 statutory scheme

establishes separate and adequate procedures for judicial review of the

Department’s actions, the APA cannot create an escape hatch for Bombardier.

Bombardier must complete administrative proceedings in the Department before

seeking judicial review. And, even then, it must seek judicial review in the courts

of appeal, not before this Court.

Id. at 39 (footnote omitted).

[Editor’s note: The administrative action was concluded by the ALJ’s approval of a settlement agreement. See

Sobhani v. Bombardier Aerospace Corp., 2014-AIR-00017 (ALJ Oct. 7, 2016).]

U.S. CITIZEN STATIONED IN FRANCE; ALJ FINDS THAT BECAUSE KEY

ELEMENTS OF COMPLAINT DEMONSTRATED A SUBSTANTIAL CONNECTION

WITH THE U.S. DOMESTIC AVIATION SYSTEM, THE COMPLAINT WAS A

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TERRITORIAL CLAIM FOR RELIEF, AND THEREFORE IT WAS NOT NECESSARY

TO REACH THE ISSUE OF WHETHER AIR21 WHISTLEBLOWER PROVISION HAS

EXTRATERRITORIAL APPLICATION

In Dos Santos v. Delta Airlines, Inc., 2012-AIR-20 (ALJ Jan. 11, 2013), the Complainant was a

U.S. citizen working as an aircraft maintenance technician at Charles de Gaulle airport in Paris,

France. He filed an AIR21 whistleblower complaint, and an amended complaint, alleging that he

suffered a hostile work environment and was denied numerous promotions in retaliation for

reporting to his employer and the FAA that his supervisor had falsified FAA safety clearance

documents. Before the ALJ, the Respondent filed a motion to dismiss on the ground that the AIR21

whistleblower provision does not apply extraterritorially to employees employed outside the U.S.

The ALJ noted that issue of whether AIR21's whistleblower provision protects employees of a

covered air carrier when they are stationed outside the territorial United States is a question of first

impression. The ALJ found that the parties appeared to agree that the two-part test announced in

Morrison v. National Australian Bank, Ltd., 130 S. Ct. 2869 (2010) applied: (1) does the statutory

provision reach extraterritorial claims? (2) given the facts alleged, is extraterritorial application of

the statute required to enforce the complaint? The ALJ reviewed Morrison and the subsequent

application of that standard, and found particularly instructive the ARB's decision in Villanueva v.

Core Laboratories, NV, ARB No. 09-108, ALJ No. 2009-SOX-6 (ARB Dec. 22, 2011) (en banc),

in which the ARB reordered the analysis and adopted a multifactor approach to the second

Morrison step. The ALJ, following the Villanueva method of applying the Morrison test, found

that the Complainant's complaint falls within the focus of AIR21 as a whole and Section 42121

specifically, and that enforcement of the complaint does not require extraterritorial application of

the statute.

The ALJ, looking to statutory sources, found that the general focus of AIR21 is to ensure the safety

of the air traveling public by strengthening the United States' aviation system. Moreover, the

legislative history both supported that the general focus of AIR21 is to bring about fundamental

improvements in air safety, and that Congress intended to achieve that goal by regulating the air

carriers that operate within the domestic aviation system and under the purview of FAA

regulations. In regard to Section 42121's purpose, the ALJ found it is not primarily a "labor law,"

but rather as a means for incentivizing airline employees to speak up when they observe violations

of Federal aviation safety laws. The ALJ concluded:

Upon review of the factors identified in Villanueva and assuming all facts asserted

by Complainant to be true, I find that the instant complaint alleges a claim that falls

squarely within both focuses of congressional concern, and therefore the complaint

can be enforced without applying Section 42121 extraterritorially. The instant

complaint concerns an employee of a U.S.-based air carrier that is subject to FAA

regulations who reported to the FAA and company officials that his manager

violated Federal aviation safety laws by fraudulently clearing aircraft as safe for air

travel. Other than the location of the employee's position, each key element of

Complainant's complaint has significant interaction with the United States aviation

system, and, heedful of Section 42121's role as a means for safeguarding the U.S.

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aviation system, it is clear that circumstances of the complaint place it within the

scope of claims that Congress intended to enforce.

Slip op. at 26. In regard to the location of the protected activity and the underlying violation, the

ALJ found that although some of the recipients of the Complainant's protected communications

were located in Europe, several others, including the FAA and the Respondent's safety and

compliance department, were located in the U.S. Although the complained of conduct (falsification

of aircraft release forms) occurred abroad, those actions directly implicated Federal aviation safety

regulations. Those actions put the Respondent in violation of an FAA regulation and presented a

potential safety hazard for any U.S. passengers and for persons near the path of the aircraft as it

entered U.S. airspace upon returning from France.

In regard to the location of the retaliatory actions, the complaint alleged that the denials of the

Complainant's promotion applications were made by officials of the Respondent based in the U.S.

The harassment that allegedly occurred at Charles de Gaulle airport was repeatedly reported to

officials both at the airport and in the U.S. The ALJ rejected the Respondent's contention that the

place where the adverse action impacts or affects the employee is where the adverse action occurs,

and found that an adverse action occurs where the employer makes the decision to take the action.

In regard to the location of the employer and employee, the ALJ found that "[n]either the location

of the employee's job, nor the location of the employer, is conclusive of the territoriality of this

complaint, because ... Section 42121 is not chiefly a labor law." Slip op. at 28. The ALJ explained:

In contrast to Title VII ..., Section 42121 is not principally focused on regulating

labor relationships, standards or conditions, and to the extent that AIR21 exhibits a

domestic focus, it is the domestic aviation system (and the actors within it) that are

the objects of the statute's solicitude. Consequently, because Section 42121's

regulation of employment relationships is a secondary means for achieving the

statute's primary ends, the physical locations of the employee and the employer are

relevant, but not determinative, factors. Their value in my analysis depends on the

extent that they evidence whether the instant complaint falls within or outside the

focus of congressional concern in enacting AIR21 and Section 42121. And, as

explained fully above, the primary focus of AIR21 is safeguarding the United

States' aviation system, while Section 42121 furthers this purpose by strengthening

airlines' compliance with Federal aviation safety laws by incentivizing airline

employees to speak out when evidence of violations arise. So while it is relevant

that Complainant worked and observed violations of Federal Aviation

Administration safety laws and regulations at an overseas location, it is even more

relevant that Complainant works for, and reported the legal failings of, a major

American air carrier that is a key participant in the American aviation system. It is

significant that Respondent is, and Complainant is an employee of, a U.S.-based,

FAA-certified air carrier under 14 C.F.R Part 121, the activities of which are subject

to Federal aviation safety regulations, and whose compliance with said regulations

is the very reason Congress enacted Section 42121.

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Slip op. at 28-29 (footnote omitted).

Because the ALJ found that enforcement of the instant complaint did not require extraterritorial

application of Section 42121, he found that he did not need to assess whether Section 42121

extends to extraterritorial claims.

JURISDICTION; COVERAGE IS NOT A JURISDICTIONAL ISSUE

In Broomfield v. Shared Services Aviation, 2004-AIR-20 (ALJ Aug. 9, 2004), the ALJ observed

that the issue of whether the Respondent is an air carrier covered by AIR21 is an issue of coverage

rather than jurisdiction.

•

Authority of ALJ and ARB to invalidate employer policy

THE ALJ AND ARB DO NOT HAVE THE AUTHORITY TO INVALIDATE EMPLOYER

POLICY OR DECLARE IT UNLAWFUL. HOWEVER, THE ALJ CAN INSTRUCT

EMPLOYERS TO ABATE VOLITATIONS WHEN THE COMPANY’S POLICY

VIOLATES THE STATUTE WHEN APPLIED.

In Hoffman v. NetJets Aviation, Inc., ARB No. 09-021, ALJ No. 2007-AIR-7 (ARB Mar. 24,

2011), the Complainant argued on appeal that the ALJ erred when he refused to consider whether

a policy of the Respondent's Flight Operation Manual requiring pilots to inform management

before writing up safety issues violated a federal aviation regulation, or whether a policy barring

recordings by employees relating to the Respondent's business was unlawful because it did not

specifically exclude protected activity under AIR21. Rather, the ALJ only considered whether the

Respondent had applied its policies to the Complainant in a manner that violated AIR21. The ARB

agreed with the ALJ's analysis. The ARB stated that under AIR21, it can hear complaints of alleged

discrimination in response to protected activity and, upon finding a violation, order the employer

to take affirmative action to abate the violation. Because the Complainant failed to prove a

violation of AIR 21, it had no power to declare the policies invalid or unlawful. The ARB thus

agreed with the ALJ that he had to determine only whether the Respondent discriminated or

retaliated in applying its policies to the Complainant. One dissenting member indicated that she

would have declared the Respondent's recordation policy, as written, illegal as a means of

affirmative relief.

•

Employer’s interests and protection of pilots

AIR21 POLICIES: EMPLOYER’S MANAGEMENT INTERESTS; PILOT RECORD

IMPROVEMENT ACT

In Hirst v. Southeast Airlines, 2003-AIR-47 (ALJ May 26, 2004), the ALJ found that the

Complainant was discharged in violation of the employee protection provision of AIR21 when he

called the Respondent's dispatcher to question an increase in the maximum gross weight of the

aircraft he was to fly from 105,000 to 108,000 pounds. Complainant was referred to a Captain who

assured the Complainant that he was confident that the increase was correct and in compliance

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with FAA regulations. Complainant requested that appropriate written documentation be faxed to

him, but the Captain directed Complainant to fly the aircraft. Complainant refused and the Captain

directed Complainant to report to Respondent's offices the next day to turn in his manuals and

identification. Although the Respondent disputed whether the Complainant was thereafter

discharged, the ALJ found that the record established that he was. The ALJ's decision contains a

discussion of the statutory history of the whistleblower provision of AIR21 and of the inherent

conflict of the interests protected by that law with an airline management's goals. The ALJ wrote:

Regulations obliging pilots to record or report irregularities engender conflicts with

managers trying to ensure on time performance, and maximize the number of

revenue legs flown; management goals suffer when recorded deficiencies have to

be corrected. See generally, John J. Nance & Charles David Thompson, The Pilot

Records Improvement Act of 1996: Unintended Consequences, 66 J. Air L. & Com.

1225 (2001). Traditionally, a pilot facing the dilemma of reporting irregularities or

antagonizing management could resign or accept termination rather than comply

with pressure to overlook dangerous conditions. Before 1996, a pilot who resigned

or was terminated in these circumstances could apply to another air carrier and give

his explanation for the previous job separation or loss. See Nance & Thompson,

supra, at 1226-28. The Pilot Record Improvement Act of 1996 (PRIA) complicates

the pilot's situation, for PRIA requires air carriers to report the records of former

employees to prospective airline employers. 49 U.S.C.A. § 44703(h)(1) (2003). An

unfavorable entry in the employment record, especially one that an air carrier

terminated the pilot for "unsatisfactory performance," becomes permanent and

public, with little meaningful opportunity for explanation, and potentially ruinous

consequences for honest and competent pilots.

Id.; Nance &Thompson, supra at 1236.

The statutes and regulations governing air commerce assign safety the highest priority. See 49

U.S.C.A. § 40101(a)(1) and (3), (d)(1) (2003). PRIA minimizes the possibility that a pilot with

dangerously flawed judgment may obtain employment with an airline that does not know about

earlier instances of incompetence, by making pilots' personnel files available to later potential

employers. AIR 21 serves as a sort of counterbalance. It promotes safe air commerce by protecting

pilots (and other airline employees) from implicitly or overtly coercive memoranda placed in their

personnel files to discourage reports about deficiencies in operations or equipment. Both PRIA

and AIR 21 reflect the central position pilots occupy in implementing the Congressional policy of

making air travel as safe as possible.

Federal law confers great responsibility on a pilot in command, and commensurate authority. "The

pilot in command of an aircraft is directly responsible for, and is the final authority as to the

operation of that aircraft." FAR 91.3. The pilot has a non-delegable duty to ensure an aircraft is

airworthy.... Id.

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12

III. BURDEN OF PROOF AND PRODUCTION

•

Prima facie case

SPLIT ARB PANEL HOLDS THAT ALJ ERRS BY NOT CONSIDERING SOX CLAIM

IN TERMS OF PRIMA FACIE CASE

In Fordham v. Fannie Mae, ARB No. 12-061, ALJ No. 2010-SOX-51 (ARB Oct. 9, 2014), a split

panel of the ARB indicated that an ALJ errs in not analyzing the case in terms of a prima face case.

The ARB panel indicated that the ALJ's error was understandable because the ARB had been

inconsistent in speaking about the showing required at the investigatory and the adjudicatory stages

of a SOX case. The panel, quoting Bechtel v. Administrative Review Board, USDOL, 710 F.3d 443

(2d Cir. 2013), indicated that a prima facie case is merely a term referring to the four elements of

a whistleblower complaint, and that "'[T]he same basic four-part framework of the

complainant's prima facie case applies not only when deciding whether the allegations are legally

sufficient, see 29 C.F.R. § 1980.104(e)(2), but also when an ALJ considers whether the

complainant has satisfied his or her evidentiary burden under 49 U.S.C.A. § 42121(b)(2)(B)(iii).'''

The ARB panel made a distinction between a showing sufficient to raise a prima facie inference at

the investigatory stage, and the elements of a prima facie case at the adjudicatory stage.

The Fordham panel stated: "at the evidentiary stage the complainant is required to prove the

four prima facie elements by a preponderance of the evidence." Id., USDOL/OALJ Reporter at

19. See also id. at 17 (ALJ's failure to analyze the evidence in terms of a prima facie case may be

due, at least in part, to the ARB's confusing and inconsistent use of terms); id. at 20 (for a

complainant to prove at hearing before an ALJ a prima facie case of retaliation through

circumstantial evidence, that evidence must establish by a preponderance of the evidence that the

protected activity was a contributing factor in the adverse action.).

[Editor's Notes: In earlier statements from the ARB, it was indicated that an ALJ errs analytically when considering

whether a complainant made out a prima facie case following an evidentiary hearing on the merits - the question at

that stage only being whether the complainant met his or her burden of proof by a preponderance of the evidence. See,

e.g, Henrich v. Ecolab, Inc., ARB No. 05-030, ALJ No. 2004-SOX-51 (ARB June 29, 2006), slip op. at 16 ("Merely

presenting a prima facie case does not entitle a complainant to prevail, but merely forces a respondent to articulate its

reason or reasons for an unfavorable personnel action. Once a respondent has done so, and a full hearing has been

held, the prima facie case analysis is no longer relevant."); Clemmons v. Ameristar Airways, Inc., ARB Nos. 05-048,

05-096, ALJ No. 2004-AIR-11 (ARB June 29, 2007) (ALJ erred in analytical approach by considering whether the

complainant proved a prima facie case by a preponderance of the evidence; rather, once a case has proceeded to

hearing, a complainant's burden is to prove by a preponderance of evidence ("demonstrate") that the protected activity

was a contributing factor in the alleged adverse action); Adornetto v. Perry Nuclear Power Plant, 1997-ERA-16 (ARB

Mar. 31, 1999) (once a case has been tried fully on the merits, it no longer serves any analytical purpose to address

and resolve the question of whether the complainant presented a prima facie case. Instead, the relevant inquiry is

whether the complainant prevailed by a preponderance of the evidence on the ultimate question of liability).

The Fordham decision was primarily about what evidence should be weighed in determining whether a complainant

had established "contributing cause" by a preponderance of the evidence. In Powers v. Union Pacific Railroad Co.,

ARB No. 13-034, ALJ No. 2010-FRS-30 (ARB Oct. 17, 2014), the ARB provided notice that it will review, en banc,

the "contributory factor" analysis addressed in Fordham. Although Fordham was a SOX case, and Powers is a FRSA

case, both are analytically grounded in the burdens of proof specified in AIR21.]

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13

ALJ DECISION; FACT THAT ALJ ERRONEOUSLY COMMENCED DECISION WITH

DISCUSSION OF PRIMA FACIE CASE DOES NOT RENDER THE DECISION

UNREVIEWABLE WHERE THE ALJ APPLIED THE CORRECT PROOF STANDARDS

IN THE REMAINDER OF THE DECISION

In Luder v. Continental Airlines, Inc., ARB No. 10-026, ALJ No. 2008-AIR-9 (ARB Jan. 31,

2012), the Respondent argued on appeal that the ALJ committed reversible error by holding the

Complainant responsible for producing only prima facie evidence of retaliation, rather than

proving such retaliation by a preponderance of the evidence. The ARB found that the ALJ had

commenced his legal analysis under AIR 21 with an erroneous statement of the respective burdens

of proof, but used the proper proof standards in the remainder of the decision. "Thus, unlike the

situation in Clemmons v. Ameristar Airways[, ARB No. 05-048, ALJ No. 2004-AIR-11 (ARB June

29, 2007)] cited by Continental, the ALJ's initial misstatement of the burdens of proof standard in

this case does not present a situation where the ARB is unable to ascertain whether the ALJ

properly applied AIR 21's burden of proof requirements."

•

ALJ errors in analytical framework or credibility determinations

ALJ'S LACK OF PRECISION IN ANALYTICAL FRAMEWORK COMPELLED

REMAND

In Clemmons v. Ameristar Airways, Inc., ARB Nos. 05-048, 05-096, ALJ No. 2004-AIR-11

(ARB June 29, 2007), the ARB remanded for additional proceedings where the ALJ made four

errors of law in analyzing the Complainant's AIR21 whistleblower complaint. Specifically, the

ALJ erred when he (1) appeared to have merged the Respondent' burden of production with its

later burden to prove by clear and convincing evidence that it would have taken the adverse action

absent protected activity; (2) held that the Complainant proved a prima facie case by a

preponderance of the evidence (rather, once a case has proceeded to hearing, a complainant's

burden is to prove by a preponderance of evidence ("demonstrate") that the protected activity was

a contributing factor in the alleged adverse action); (3) appeared to have found that a finding of

pretext compels a finding of discrimination; and (4) failed to consider whether the Respondent

proved that it would have terminated the Complainant absent protected activity. The ARB

acknowledged that the ALJ's errors may have been simply imprecision; but that imprecision

created uncertainty about the ALJ's findings that compelled a remand.

BURDEN TO SHOW THAT ALJ'S CREDIBILITY DETERMINATIONS WERE

INCREDIBLE OR UNREASONABLE

Where an ALJ credits the testimony of the respondent's witnesses, a complainant who maintains

on ARB review that those witnesses were not truthful has the burden of demonstrating that the

ALJ's credibility determinations were incredible or unreasonable. Gary v. Chautauqua Airlines,

ARB No. 04-112, 2003-AIR-38 (ARB Jan. 31, 2006) (citing Lockert v. U.S. Dept. of Labor, 867

F.2d 513, 519 (9th Cir. 1989).

•

Burdens of proof in AIR21 whistleblower complaint; general outline

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14

In Brune v. Horizon Air Industries, Inc., ARB No. 04-037, ALJ No. 2002-AIR-8 (ARB Jan. 31,

2006), the ARB restated the procedures and burdens of proof applicable to an AIR21

whistleblower complaint, which had earlier been detailed in Peck v. Safe Air Int'l, Inc., ARB No.

02-028, ALJ No. 2001-AIR-3, slip op. at 6-18 (ARB Jan. 30, 2004). The Board distinguished the

procedure followed at the OSHA investigatory stage and at the hearing stage before the OALJ and

the ARB, with the essential difference being that to secure an investigation, a complainant needs

only to raise an inference of unlawful discrimination (i.e., establish a prima facie case), while at

the adjudicatory stage a complainant must prove unlawful discrimination. The ARB wrote that:

This is not to say, however, that the ALJ (or the ARB) should not employ, if appropriate, the

established and familiar Title VII methodology for analyzing and discussing evidentiary burdens

of proof in AIR21 cases. The Title VII burden shifting pretext framework is warranted where the

complainant initially makes an inferential case of discrimination by means of circumstantial

evidence. The ALJ (and ARB) may then examine the legitimacy of the employer's articulated

reasons for the adverse personnel action in the course of concluding whether a complainant has

proved by a preponderance of the evidence that protected activity contributed to the adverse action.

Thereafter, and only if the complainant has proven discrimination by a preponderance of evidence

and not merely established a prima facie case, does the employer face a burden of proof. That is,

the employer may avoid liability if it "demonstrates by clear and convincing evidence" that it

would have taken the same adverse action in any event. Brune, supra, slip op. at 13-14 (footnotes

omitted). In Brune, the ALJ erred in that he required the Complainant to prove his case according

to the prima facie case standard, rather than the preponderance of the evidence standard. It is not

enough at the hearing phase for a complainant merely to establish a rebuttable presumption that

the employer discriminated. Rather, a complainant must prove by a preponderance of the evidence

protected activity, adverse action and causation.

The ALJ also erred because, once the Complainant established a prima facie case, the ALJ assigned

the Respondent the burden of demonstrating by clear and convincing evidence that it would have

taken the same adverse personnel action in the absence of his employee's protected activity. Rather,

a respondent's burden upon a complainant's establishment of a prima face case is one

of production, not proof -- the respondent needs only to articulate some legitimate, nondiscriminatory reason for its actions -- the respondent's "clear and convincing evidence" burden of

proof only arises if the complainant has proven discrimination by a preponderance of the evidence.

•

Applicable decisional law; burdens of proof and production

In Davis v. United Airlines, Inc., 2001-AIR-5 (ALJ July 25, 2002), the ALJ reviewed the

legislative history of AIR21's whistleblower provision, and concluded that the decisional law

developed under the ERA, the Whistleblower Protection Act, and the whistleblower provisions of

federal environmental statutes, provide the framework for litigation arising under AIR21.

The ALJ then set out a statement of the burden of proof standards, similar to the statement of such

by the ALJ in Taylor v. Express One International, Inc., 2001-AIR-2 (ALJ Feb. 15, 2002) , with

some additional clarifications. For example, the ALJ noted that the "contributing factor" element

is only applicable to the establishment of a prima facie case.

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15

BURDEN OF PROOF AND PRODUCTION IN AIR21 CASES; TITLE VII

METHODOLOGY

In Peck v. Safe Air International, Inc., ARB No. 02-028, ALJ No. 2001-AIR-3 (ARB Jan. 30,

2004), the ARB outlined the scope of coverage, procedures, and burdens of proof under the AIR21

whistleblower provision. The Board emphasized that the law imposes a "gatekeeper" standard

prior to hearing during the preliminary stage of the proceeding -- the required "prima face

showing" of section 42121(b)(2)(B)(i). The standard that ALJs apply at hearing and that the ARB

applies on review, however, is as follows: "If a complainant 'demonstrates,' i.e., proves by a

preponderance of the evidence, that protected activity was a 'contributing factor' that motivated a

respondent to take adverse action against him, then the complainant has established a violation of

AIR21 section 519(a). 49 U.S.C.A. § 42121(b)(2)(B)(iii)." (citation omitted). The Board wrote

that the distinction, then, between standards applied for purposes of investigation and adjudication

of a complaint concerns the complainant's burden: To secure investigation a complainant merely

must raise an inference of unlawful discrimination; to prevail in an adjudication a complainant

must prove unlawful discrimination.

The ARB also observed that the AIR21 whistleblower provision was modeled on section 211 of

the ERA, and that the ARB had found in Kester v. Carolina Power & Light Co., ARB No. 02-007,

ALJ No. 2000-ERA-31, slip op. at 5-8 and nn.12-19 (ARB Sept. 30, 2003), that the Title VII

methodology for analyzing and discussing evidentiary burdens of proof was appropriate to use in

ERA section 211 cases. The ARB, quoting its decision in Kester, wrote:

"[T]he Title VII burden shifting pretext framework [is] warranted in [the] typical [ERA]

whistleblower case where the complainant initially makes an inferential case of discrimination by

means of circumstantial evidence." Id. at 7 n.17. The ARB may thus examine the legitimacy of the

employer's articulated reasons for the adverse personnel action in the course of concluding whether

a complainant in an ERA case has proved by a preponderance of the evidence that protected

activity contributed to the dismissal. Id. See McDonnell Douglas Corp. v. Green, 411 U.S. 792

(1973). Unless a complainant proves that the employer fired him in part because of his protected

activity, it is unnecessary to proceed to determine whether the employer has demonstrated by clear

and convincing evidence that it would have taken the same unfavorable personnel action in the

absence of the protected activity. Kester, slip op. at 8.

The Board then held that the same approach is applicable under AIR21 section 519. See 49

U.S.C.A. § 42121(b)(2)(B)(iii)-(iv).

IV. PROTECTED ACTIVITY

•

In general

PROTECTED ACTIVITY; ARB SUMMARIZES CURRENT STATE OF THE LAW ON

WHAT CONSTITUTES PROTECTED ACTIVITY UNDER AIR21; INFORMATION

PROVIDED MUST BE SPECIFIC AS TO AIRCRAFT SAFETY; AIR21 IS NOT A

GENERAL REMEDY FOR EMPLOYMENT GRIEVANCES

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16

PROTECTED ACTIVITY; WHERE EMPLOYER ACCEPTED COMPLAINANT’S

SUGGESTION TO IMPROVE CLARITY OF POLICY ON AVOIDING DAMAGE TO

PLANE DOORS, THE ARB FOUND THAT THE SUBJECTIVE AND OBJECTIVE

REASONABLENESS OF COMPLAINANT’S BELIEF WAS UNDISPUTED

PROTECTED ACTIVITY; COMPLAINANT’S PRINTING OF DOCUMENTS TO

PROVIDE TO OSHA WAS PROTECTED ACTIVITY UNDER AIR21’S ELEMENT OF

“ABOUT TO PROVIDE” ANY INFORMATION ABOUT AN ALLEGED VIOLATION

OF FEDERAL LAW RELATED TO AIR SAFETY

In Forrand v. FedEx Express, ARB No. 2019-0041, ALJ No. 2017-AIR-00016 (ARB Jan. 4,

2021) (per curiam), the ARB affirmed the ALJ’s Decision and Order denying Complainant’s

AIR21 retaliation claim in a per curiam decision in which the ARB limited its discussion to

Complainant’s arguments on appeal and to clarification of certain of the ALJ’s rulings.

In regard to protected activity, the ARB initially summarized the legal standard under AIR21:

Protected activity under AIR 21 has two elements: (1) the information that the

complainant provides must involve a purported violation of a regulation, order, or

standard of the FAA or federal law relating to air carrier safety, though the

complainant need not prove an actual violation; and (2) the complainant’s belief

that a violation occurred must be subjectively held and also objectively reasonable.

The information provided to the employer or federal government must be specific

in relation to a given practice, condition, directive, or event that affects aircraft

safety. A complainant’s belief is objectively reasonable if it is one that a person of

similar training and experience would hold.

Slip op. at 3-4 (footnotes omitted). In regard to the reasonableness of the complainant’s belief, the

ARB noted “the obvious fact that the text of the statute directs us to consider whether the safety

of the flying public is, or might be, enhanced by the whistleblower’s behavior. Air 21 is not a

general remedy for employment grievances unrelated to air safety.” Id. at 3, n.8.

The ALJ found that Complainant established one instance of protected activity. The ARB,

however, found three instances. The ARB only discussed the two additional instances in its

decision.

First, the ARB noted that—although the ALJ had discussed an incident in which Complainant had

e-mailed his supervisor about the wording of a policy statement on avoiding damage to plane doors

by moveable elevators that resulted in the policy being modified to improve clarity based on

Complainant’s feedback—the ALJ had not considered whether this was protected activity. The

ARB determined that “Complainant’s e-mail to his supervisor about the policy is protected activity

because it relates to protecting the airplane’s doors and, obviously, to air safety. The Complainant’s

subjective belief and objective reasonableness of that belief are undisputed because Respondent

accepted Complainant’s suggestion and took action in response to it.” Id. at 4.

Second, the ALJ found that Complainant’s printing of documents at one of Respondent’s facilities

for the purpose of supplying them to OSHA was “not protected activity because Complainant’s

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17

‘individual steps’ of printing the documents were not discreet protected activity under the

Act.” Id. at 4-5 (footnote omitted). The ARB, however, found that this was protected activity

under the “about to provide” element of AIR21:

Th[e ALJ’s finding] is correct as far as it goes, but AIR 21 protects an employee

from retaliation when the employee is “about to provide” any information about an

alleged violation of Federal law related to air safety. The Board has held that “an

employee engages in protected activity if he attempts to provide information of

retaliation that violates AIR 21.” In this instance, Complainant printed documents.

In printing the specific documents he did, Complainant was “about to provide”

relevant information for his AIR 21 complaint, which concerned an alleged

violation of Federal law related to air safety. Complainant therefore engaged in

protected activity.

Id. at 5 (footnotes omitted). The ARB noted, however, that this was harmless error by the ALJ

because Complainant had not been subjected to retaliation.

PROTECTED ACTIVITY; DIFFICULTIES EXPERIENCED BY COMPLAINANT IN

MAKING TRIP TO DRUG TESTING FACILITY FOR RANDOM DRUG TEST,

ALTHOUGH ARDUOUS, DID NOT FALL WITH AIR21 PROTECTIONS

In Antonellis v. Republic Airways, ARB No. 2019-0046, ALJ No. 2018-AIR-00024 (ARB Feb. 8,

2021) (per curiam), Complainant, who worked as a First Officer for Respondent, filed an AIR21

complaint alleging that Respondent retaliated against her after she submitted Aviation Safety

Action Program (ASAP) report concerning a flight related concern, and after she provided notice

of intent to file an ASAP related to difficulties she experienced in traveling to a drug testing

facility.

Prior to the flight in question, Complainant had been among 350-400 employees who could be

selected for a random drug test by a third-party drug testing administrator through its randomgenerator program. Complainant was informed of her selection for a random drug test two days

after the flight-related ASAP report. Complainant experienced difficulties on her way to the drug

testing facility, and informed Respondent that she was going to file an ASAP report concerning

the trip conditions. Upon arriving at the facility, she was unable to produce a sufficient specimen,

and although informed that she needed to stay to follow the “shy bladder” procedure, she informed

Respondent that she could not produce a sufficient specimen and needed medical

attention. Although Respondent did not give her permission to leave the drug test, she

left. Respondent suspended Complainant, and later terminated her employment for the test

refusal. A union grievance was filed, and Complainant was reinstated pending the outcome of a

FAA investigation. After the FAA completed the investigation and revoked Complainant’s license

and medical certificate, Respondent issued a second letter of termination.

The ALJ found that the flight-related ASAP was protected activity under AIR21, but not the notice

of intent to file an ASAP related to the trip to the drug testing facility. The ALJ found that

Complainant failed to prove by a preponderance of the evidence that flight related ASAP was a

contributing factor in her selection for a random drug test, in Respondent reporting her as a drug

test refusal, or in Respondent’s decision to terminate her employment.

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18

On appeal, Complainant argued that the ALJ erred in finding that the notice of intent to file an

ASAP about the travel conditions to the drug testing facility was not protected activity, and in

finding that the other ASAP report was not a contributing factor in the adverse employment

actions. Complainant also challenged the ALJ’s findings of fact and credibility determinations.

The ARB found that the ALJ’s decision was supported by substantial evidence, and that

Complainant had not shown an abuse of discretion or reversible error by the ALJ. The ARB

summarized: “We recognize that the trip to the testing facility was arduous but those activities

and conditions do not fall within the statute’s protections. Most importantly, there was simply no

evidence that Complainant’s protected conduct was at all linked to her selection to be drug tested.

They were wholly separate, to put it simply, incidences. The record is clear on this point.

Accordingly, we summarily AFFIRM the ALJ’s D. & O.” Slip op. at 6.

PROTECTED ACTIVITY; COMPLAINANT’S RENEWED RAISING OF CONCERNS

THAT PUBLIC POSTING OF FLIGHT AND PACKAGE TRACKING DATA COULD

ASSIST TERRORISTS WAS NOT SUBJECTIVELY OR OBJECTIVELY REASONABLE

WHERE THE ISSUE WAS LONG KNOWN, AND AIR SAFETY AGENCIES HAD NOT

TAKEN ACTION ON THE QUESTION; IT IS THE FAA, AND NOT THE AIRLINES,

THAT POSTS THE DATA; ALTHOUGH AIRLINES MAY OPT OUT OF SUPPLYING

THE DATA, TO DO SO WAS NOT ILLEGAL; MERE POTENTIAL FOR IMPROVING

SECURITY DOES NOT MEAN AIRLINE WAS VIOLATING A LAW OR REGULATION

In Estabrook v. Administrative Review Board, USDOL, No. 19-60716 (5th Cir. June 30, 2020)

(per curiam), the Fifth Circuit held that substantial evidence supported the ALJ’s finding that

AIR21 protected activities had not contributed to Respondent FedEx’s decisions to ground

Estabrook and to require a compulsory medical evaluation.

The court first addressed the ALJ’s findings that comments made by Estabrook, who was an

experienced pilot, during an August 9, 2013 meeting were not protected activity. Estabrook had

demanded a meeting with FedEx’s CEO to report “something related to 9-11.” A meeting with

senior FedEx officials (but not the CEO) took place on August 9. During the meeting Estabrook

recommended that FedEx stop making flight- and package-tracking data available to the public

because terrorists could make use of that data to detonate a bomb. Estabrook had raised the same

claim in 2002. Estabrook also brought up that he had heard that a former colleague who had

attempted to hijack a plane had converted to Islam while in jail. Estabrook thought that FedEx

should go to DOJ to request eavesdropping on the former colleague, but offered no other basis for

this view than his belief that the former colleague was Muslim.

Because Estabrook had not challenged DOL’s contention that to be protected, an employee’s

statements indicating a belief that air-carrier safety rules exist must be subjectively and objectively

reasonable, the court assumed, without deciding, that this was the correct standard. The court noted

OSHA’s observation that this standard was in line with the Fifth Circuit’s interpretation of the

SOX whistleblower provision, but also noted that the statutory language was different—SOX

referring to reports that a complainant “reasonably believes constitutes a violation” of certain

securities law—whereas AIR21 only describes the reporting of “any violation or alleged

violation.”

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19

The ALJ found that Estabrook’s comments were not subjectively reasonable because he had

known about the public availability of tracking data for over 10 years, and that for several years

U.S. intelligence agencies had been aware of terrorist’s plans to use such data, but the agencies

had taken no steps to curtail it. As to objective reasonableness, the ALJ found that the availability

of tracking information was well known to the general public, and yet aviation safety agencies had

not taken action on the question. The court observed: “it is the FAA—not FedEx—that makes

flight-tracking data available to the public. True, carriers can opt out of public disclosure. But all

that matters is that the FAA permits disclosure of the data, so that disclosure does not violate the

law. And, as the ALJ noted, the mere potential for improving security ‘does not mean that [FedEx]

was violating any law or regulation.’” Slip op. at 7. The court thus did not disturb DOL’s

conclusion that the August 9 comments were not protected activity under AIR21.

PROTECTED ACTIVITY; ALJ ERRED IN FINDING THAT RETALIATORY ACTIONS

NOT INVESTIGATED BY OSHA WERE NOT BEFORE HIM FOR THE DE NOVO

HEARING

In Swint v. NetJets Aviation, Inc., ARB No. 2017-0051, ALJ Nos. 2014-AIR-00021, 2016-AIR00011 (Apr. 27, 2020) (per curiam), the ARB summarily affirmed the ALJ’s conclusion that none

of the employment actions described in Complainant’s AIR21 complaint were taken in retaliation

for protected activity. The ARB, citing 29 C.F.R. § 1979.107(b), stated that the ALJ erroneously

concluded that two of the alleged retaliatory actions were not before him because they were not

investigated by OSHA. The ARB, however, found the error harmless because those claims failed

on alternative grounds.

PROTECTED ACTIVITY; SUBSTANTIAL EVIDENCE SUPPORTED ALJ’S

DETERMINATION THAT COMPLAINANT DID NOT HAVE AN OBJECTIVELY

REASONABLE BELIEF THAT A VIOLATION EXISTED OR WAS LIKELY TO

OCCUR, WHERE NONE OF SAFETY CONCERNS RAISED BY COMPLAINANT

WERE IMMINENT OR ENTIRELY TRUTHFUL

In Kreb v. Jackson Jet Center, ARB No. 2018-0065, ALJ No. 2016-AIR-00028 (ARB Sept. 28,

2020) (per curiam), the ARB found that the ALJ’s determination that Complainant did not engage

in protected activity under AIR21 was supported by substantial evidence. The ALJ had found that

Complainant did not have an objectively reasonable belief that a violation existed or was likely to

occur considering the knowledge available to a reasonable person in the same factual

circumstances. The ARB stated: “Critical in this regard are the ALJ’s findings, supported by the

substantial evidence of record, that none of the safety concerns were imminent or entirely truthful.

The record shows that a pilot with the same experience and training would not have thought the

cited safety concerns were likely or imminent violations of federal aviation standards, but at most

possibilities dependent on factors that were unknown or unlikely at the time Complainant raised

his concerns. Complainant offered no evidence that a pilot with his training and experience would

have agreed that accepting the July 9 flight assignment would have posed a safety risk.”

PROTECTED ACTIVITY; INFORMATION PROVIDED BY COMPLAINANT ONLY

HAS TO BE RELATED TO ANY VIOLATION OR ALLEGED VIOLATION;

COMPLAINANT NEED NOT HAVE WAITED FOR AN FAA VIOLATION TO OCCUR

FOR A REPORT TO BE PROTECTED ACTIVITY

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20

PROTECTED ACTIVITY; RULINGS OF HINDSMAN AND MALMANGER—FINDING

THAT REPORTS IN THOSE CASES WERE NOT PROTECTED ONCE

COMPLAINANTS’ KNEW THAT REPORTED MATTER WAS NOT A VIOLATION OR

HAD BEEN RESOLVED —WERE DISTINGUISHABLE IN INSTANT CASE WHERE

AT TIME REPORTS WERE MADE THE MATTER HAD NOT BEEN RESOLVED AND

COMPLAINANT’S REPORTS WERE NOT MADE SIMPLY TO “CLOAK”

COMPLAINANT WITH WHISTLEBLOWER PROTECTION

In McMullen v. Figeac Aero North America, ARB No. 2017-0018, ALJ No. 2015-AIR-00027

(ARB Mar. 30, 2020) (per curiam), Complainant, the General Manager of Respondent’s Wichita

airline components plant, filed an AIR21 retaliation complaint alleging that his employer

terminated his employment in retaliation for reporting safety violations. The ALJ found in favor

of Complainant. The ARB affirmed.

In regard to protected activity, the ARB stated:

Protected activity under AIR 21 has two elements: (1) the information that the

complainant provides must involve a purported violation of a regulation, order, or

standard of the FAA or federal law relating to air carrier safety, though the

complainant need not prove an actual violation; and (2) the complainant’s belief

that a violation occurred must be subjectively held and objectively reasonable.4

“The information provided to the employer or federal government must be specific

in relation to a given practice, condition, directive, or event that affects aircraft

safety.” Hindsman v. Delta Air Lines, Inc., ARB No. 09-023, ALJ No. 2008-AIR013, slip op. at 5 (ARB June 30, 2010).

Slip op. at 4. In the instant case, the ALJ found that Complainant engaged in protected activity

when he informed the CEO of Respondent’s parent company that Respondent’s vice-president of

sales threatened Respondent’s quality assurance manager because she refused to falsify First

Article Inspection Report (FAI) documentation in violation of a FAA regulation. Although in the

first report Complainant had not cited to a specific regulation, the ALJ found that was not necessary

and that Complainant’s concerns were well-based and reasonable.

The ALJ also found that the quality assurance manager had raised concerns about proper

paperwork, which Complainant reported to the parent company’s CEO by email, informing that

omitting information on the FAI could be considered fraud and a violation of FAA regulations.

The ARB affirmed that this communication qualified as protected activity. The ARB stated:

“Moreover, information only has to be related to any violation or alleged violation and

Complainant need not have waited for an FAA violation to occur in order to report the omission

and have whistleblower protection.” Id. at 5.

On appeal, Respondent contended that the Board’s holdings in Hindsman, supra, and Malmanger

v. Air Evac EMS, Inc., ARB No. 08-071, ALJ No. 2007-008 (ARB July 2, 2009), required a

different outcome. The Board disagreed:

In Hindsman, the Board held that the complainant could not have had a reasonable

belief that flying with the portable oxygen concentrator on board violated air safety

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21

regulations once she had confirmed that the item was permitted by the FAA. These

facts are not analogous to those in this case as McMullen was reporting potential

violations, which the ALJ found were objectively reasonable. In addition,

in Malmanger, the Board affirmed an administrative law judge’s finding that the

complainant did not have a reasonable belief that the company violated an order,

regulation, or standard of the Federal Aviation Administration or any other

provision of Federal law relating to air carrier safety. At the time he reported his

concerns to management, the complainant knew the problems had been resolved

and the ALJ found that his complaints were insincere and made to forestall what he

believed would be an adverse performance evaluation. In this case, the ALJ found

that McMullen’s concerns were sincere and not made to “cloak himself” with

whistleblower protection. Moreover, the concerns had not been resolved by the time

the Complainant reported his concerns to [the parent company’s CEO]. Thus, we

affirm the ALJ’s finding that McMullen engaged in protected activity on July 26

and 28, as well as when he filed the report to the FAA on July 30, 2014 as they are

supported by substantial evidence.

Id. 5-6.

PROTECTED

ACTIVITY;

TO

CONSTITUTE

PROTECTED

ACTIVITY,

COMPLAINANT NEED NOT ESTABLISH AN ACTUAL VIOLATION OF A FEDERAL

RULE OR REGLUATION RELATED TO AIR SAFETY, BUT MUST HAVE BOTH A

SUBJECTIVELY AND OBJECTIVELY REASONABLE BELIEF THAT A VIOATION

OCCURRED OR WAS ABOUT TO OCCUR

In Cerny v. Triump Aerostructures-Vought Aircraft Division, ARB No. 2019-0025, ALJ No.

2016-AIR-00003 (ARB Oct. 31, 2019), Complainant filed a complaint alleging that Respondent

retaliated against him in violation of AIR21’s whistleblower protection provisions for raising air

transportation safety concerns. On appeal, the only instance of protected activity preserved for

ARB review concerned an engineering report submitted by Complainant. The lead engineer had

returned the report to Complainant with a heavy set of redlines and a directive to make changes.

Complainant made some changes, but submitted a checklist of changes he refused to make.

On appeal, the Complainant argued that the ALJ erred in finding that—although Complainant had

a subjective belief that the change refusals were based on engineering science and Respondent’s

manual—it was not an objectively reasonable belief that Complainant’s checklist of declined

changes was protected activity. Complainant argued that that he need not show that a law was

actually violated, but need only prove that he had a reasonable belief that his report related to Air

carrier safety. Complainant also argued that the ALJ failed to take into account that another person

had reviewed the report after Complainant’s termination and did not have objections to

Complainant’s work. Complainant further challenged the ALJ’s credibility finding concerning the

lead engineer.

The ARB, however, affirmed the ALJ’s ALJ findings on protected activity. The ARB

acknowledged that Complainant need not prove an actual violation to engage in protected activity

under AIR 21, but only a reasonable belief that a violation of a federal rule or regulation related to

air safety occurred or was about to occur. The ARB stated that nonetheless “an employee’s

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reasonable belief is comprised of both a subjective and an objective component….” Slip op. at 8.

The ARB found that the ALJ’s findings were supported by substantial evidence. Testimony

showed that the lead engineer had another engineer review Complainant’s report, and that engineer

provided negative feedback concerning Complainant’s refusal checklist. In addition, Complainant

had not been proficient in using analytical software and there were issues throughout the report.

PROTECTED ACTIVITY; WHERE COMPLAINANT ASSISTED AND PARTICIPATED

IN NTSB INVESTIGATION OF CRASH, THIS WAS SUFFICIENT TO ESTABLISH

PROTECTED ACTIVITY UNDER § 42121(a)(4), AND IT WAS NOT NECESSARY ON

APPEAL TO DETERMINE WHETHER THE MATTTERS REPORTED WERE ALSO

PROTECTED ACTIVITY UNDER § 42121(a)(1) OR (2)

In Yates v. Superior Air Carrier LLC, ARB No. 2017-0061, ALJ No. 2015-AIR-00028 (ARB

Sept. 26, 2019) (per curiam), Respondent argued on appeal that Complainant had not established

that he engaged in protected activity when he emailed an NTSB investigator about concerns with

the NTSB’s report concerning a crash in which Complainant had been the First Officer (secondin-command), as Complainant had not identified any FAA or other air safety order, regulations or

standard that was allegedly violated. The ARB, however, agreed with the ALJ that, regardless of

whether Complainant’s reports were themselves protected activity under 49 U.S.C. § 42121(a)(1)

or (2), both Complainant’s interview with the NTSB and his later email to the NTSB qualified as

assistance or participation in a proceeding relating to carrier safety as described in 49 U.S.C. §

42121(a)(4). Because this finding was sufficient to resolve the question of protected activity, the

ALJ had correctly resolved the matter with this basic finding despite the parties’ zealous arguments

on additional facts and theories of law.

PROTECTED ACTIVITY; COMPLAINANT’S RAISING OF SECURITY CONCERNS

ABOUT FEDEX’S ONLINE PACKAGE TRACKING SYSTEM WAS NOT PROTECTED

ACTIVITY; REASONABLE BELIEF ELEMENT NOT ESTABLISHED BECAUSE

COMPLAINANT KNEW THAT THE COMPLAINED OF ACTIVITY WAS PERMITTED

BY THE FAA

In Estabrook v. Federal Express Corp., ARB No. 2017-0047, ALJ No. 2014-AIR-00022 (ARB

Aug. 8, 2019) (per curiam), Complainant was a pilot for FedEx. His refusal to fly in bad weather

and associated OSHA complaint (later withdrawn when FedEx took no disciplinary action) were

both protected activity under AIR21. However, the ARB agreed with the ALJ that, although AIR21

protects providing information about “security” even though security is not specifically mentioned

in the status, the security concerns expressed by Complainant during a meeting with management

officials did not constitute protected activity in this case. The ARB cited its decision in Hindsman

v. Delta Air Lines, Inc., ARB No. 09-023, ALJ No. 2008-AIR-013, slip op. at 5 (ARB June 30,

2010), in which it was found that a “complainant did not engage in protected activity when the

complainant knew that the FAA permitted the complained of activity.” The ARB stated that in the

instant case, Complainant “could not have had a reasonable belief that publishing low-level flight

or tracking information constituted a violation of federal air carrier safety or security laws.

Publishing some level of tracking data is an industry-wide practice and not prohibited. . . . The

FAA and other related entities had received complaints from Estabrook and others expressing

concern about this practice in 2001 and 2002, but did not prohibit the activity. Estabrook was only

suggesting a policy change for FedEx to voluntarily or proactively withdraw publishing data to

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make its safety or security procedures more effective.” Slip op. at 10 (emphasis as in original)

(footnote omitted).

PROTECTED ACTIVITY; ALLEGATION THAT COWORKERS HAD SMUGGLED

OTHER EMPLOYEES ONTO FLIGHTS WITHOUT LISTING THEM ON THE

MANIFEST SUFFICIENT TO WITHSTAND A FRCP 12(b)(6) MOTION TO DISMISS

BECAUSE THE COMPLAINANT, A CUSTOMER SERVICE REPRESENTATIVE,

COULD REASONABLY HAVE PERCEIVED THIS TO BE A SAFETY ISSUE

PROTECTED ACTIVITY; WHERE COMPLAINANT SUBMITTED MATTERS

OUTSIDE THE PLEADINGS IN RESPONSE TO A MOTION TO DISMISS, THE ARB

RULED THAT THE ALJ SHOULD HAVE CONSIDERED THE MOTION AS A MOTION

FOR SUMMARY DECISION RATHER THAN A FRCP 12(b)(6) MOTION

In Hukman v. U.S. Airways, Inc., ARB No. 15-054, ALJ No. 2015-AIR-3 (ARB July 13, 2017),

the ALJ had granted the Respondent’s motion to dismiss for failure to state a claim upon which

relief can be granted. The ALJ applied FRCP 12(b)(6). The Complainant had alleged that she

engaged in protected activity “when she reported 1) that coworkers were smuggling co-workers

onto planes without listing them on the manifest (and that this was unsafe because of weight and

balance issues), 2) that co-workers engaged in an altercation with her (which she calls the airport

rage incident), and 3) that a nurse was practicing with an expired license. The ALJ concluded that

none of these activities were protected.” Slip op. at 5. The ARB reiterated the law concerning what

constitutes protected activity under AIR21:

For activity to be protected under 49 U.S.C.A. § 42121(a)(1), a complainant must

provide information relating to a violation of a Federal Aviation Administration

(FAA) order, regulation, or standard or of any federal law relating to air carrier

safety. A complainant must have a reasonable belief in a violation and this

reasonable belief has both objective and subjective components. To prove

subjective belief, a complainant must prove that she actually “believed that the

conduct [s]he complained of constituted a violation of relevant law.” To determine

whether a subjective belief is objectively reasonable, one assesses a complainant’s

belief taking into account “‘the knowledge available to a reasonable person in the

same factual circumstances with the same training and experience as the aggrieved

employee.’”

Id. at 4-5 (citations omitted).

The ARB affirmed the ALJ’s findings that the airport rage incident and the report about a nurse’s

expired license did not state claims with respect to protected activity because these reports did not

purport to involve violations of FAA orders, regulations, or standards, or any federal laws relating

to air carrier safety. The ARB, however, reversed the ALJ’s conclusion that the Complainant did

not state a claim with respect to the allegation that coworkers were smuggling other employees

onto planes.

The ARB first noted that it appeared that because the ALJ had ruled on the Respondent’s motion

to dismiss under FRCP 12(b)(6), the ALJ had not considered materials submitted by the

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24

Complainant outside of her pleadings including materials attached to her request for hearing and

her response to the Order to Show Cause. The ARB found that the pleadings would have survived

a 12(b)(6) motion to dismiss because the allegation that “flights were taking off with incorrect

numbers and types of people listed on the manifest because the incorrect information touched on

the safety of the flights and because weight on a flight could reasonably be perceived to be a safety

issue to one such as [the Complainant], a customer service representative.” Id.at at 6. The ARB

also noted that, although not required to do so, the Complainant had cited 14 C.F.R. Part 121 in

her first prehearing statement in regard to weight and balance limitations.

The ARB, citing FRCP 12(d), also found that the ALJ should have considered the motion as a

motion for summary decision and considered the outside-the-pleadings submissions. The ARB

reviewed the submissions, which included many reports by the Complainant of smuggling people

onto aircraft, not counting jumpseaters, and counting adults as a children; an accident description

of a plane crash caused in party by weight and balance issues; and a CBS news article about a FAA

fine against a carrier for failing to calculate baggage weight on dozens of flights. The ARB found

that the Complainant’s pleadings and submissions showed a genuine issue of material fact as to

whether the Complainant held a reasonable belief that the weight and balance issues were

violations of the FAA regulations.

PROTECTED ACTIVITY; AIR21 DOES NOT REQUIRE PROTECTED ACTIVITY TO

RELATE “DEFINITIVELY AND SPECIFICALLY” TO SAFETY

In Hukman v. U.S. Airways, Inc., ARB No. 15-054, ALJ No. 2015-AIR-3 (ARB July 13, 2017),

in granting the Respondent’s motion to dismiss, the ALJ had found that the alleged protected

activity must implicate safety definitively and specifically. The ARB, however, cited Sewade v.

HaloFlight, Inc., ARB No. 13-098, ALJ No. 2013-AIR-9, slip op. at 8 (ARB Feb. 13, 2015), in

which the ARB held that AIR 21 does not require protected activity to relate “definitively and

specifically” to safety.

PROTECTED ACTIVITY; FAILURE TO STATE A CLAIM; SOX COUNT DISMISSED

WHERE PLAINTIFF FAILED TO ALLEGE THAT HIS COMPLAINTS ABOUT

FAILURE TO COMPLY WITH FAA REGULATIONS INCLUDED A REPORT OF A

BELIEF THAT SUCH FAILURES WERE A FRAUD ON SHAREHOLDERS

In Neely v. Boeing Co., No. 16-cv-1791 (W.D. Wash. May 15, 2018) (2018 U.S. Dist. LEXIS

81771; 2018 WL 2216093) (related to 2018-AIR-00019), the district court granted the Defendant’s

motion to dismiss for failure to state a claim on the count of the Plaintiff’s complaint that was

based on the SOX whistleblower provision. The court found that the Plaintiff’s second amended

complaint only stated that the Plaintiff made complaints regarding the Defendant’s alleged failure

to comply with FAA regulations, and did not contain an allegation that he reported his belief that

these actions were defrauding shareholders to the Defendant or to any federal agency. The Plaintiff

alleged that he filed complaints that he was being retaliated against for being a whistleblower, but

did not specifically allege that he raised any allegations of shareholder fraud prior to any alleged

retaliation. The court thus found that the Plaintiff failed to allege that he engaged in protected

activity under SOX.

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PROTECTED ACTIVITY; REPORT OF TURBULENCE ON PREVIOUS FLIGHT NOT

LOGGED BY PREVIOUS PILOT; CHALLENGE OF REFUSAL TO CONDUCT

INSPECTION

In Cont’l Airlines, Inc. v. Admin. Review Bd., USDOL, No. 15-60012 (5th Cir. Jan. 7, 2016)

(unpublished) (2016 U.S. App. LEXIS 324; 2016 WL 97461)(case below ARB No. 10-026, ALJ

No. 2008-AIR-00009), the Fifth Circuit found that substantial evidence supported the ARB’s

decision that “Continental [the Petitioner] retaliated against Luder [the AIR21 Complainant] when

it suspended him for logging turbulence on an earlier flight reported to him by a member of the

previous flight crew and triggering an inspection which resulted in a delayed flight.” Slip op. at 12.

The court noted: “To establish protected conduct, the employee must show that he reported a

violation of federal safety law. Specifically, activity is protected ’because the employee

provided…information relating to any violation or alleged violation of any order, regulation, or

standard of the [FAA].’ Moreover, the employee’s belief that a violation of federal law occurred

must be reasonable.” Slip op. at 5 (footnotes omitted).

The court found that substantial evidence supported the ARB finding that Luder reported an

alleged violation of federal law. Because he believed that the airplane went through severe

turbulence, Luder’s actions implicated federal regulations in two ways. First, by logging the

turbulence, he effectively reported a violation by the previous pilot for failing to log his encounter

with severe turbulence. Second, by challenging Continental’s refusal to conduct the inspection and

refusing to acquiesce in Continental’s objection to an inspection he reasonably believed was

required, Luder reported that Continental tried to cause him to violate FAA regulations.

The court also found that Luder’s belief that the airplane encountered severe turbulence was

reasonable. A crewmember who was on the first flight had described winds so strong they nearly

tore the wings off, sent a person to the medical clinic, and appeared on the radar as pink—the

greatest degree of turbulence. Defendant was found to have known that Luder logged the severe

turbulence and requested an inspection, as the logbook entry and triggered inspection by Luder

was the subject of a heated telephone conversation between him and Continental officials.

PROTECTED ACTIVITY IN AIR21 CASE; COMPLAINANT NEED NOT ACTUALLY

CONVEY REASONABLE BELIEF TO HIS OR HER EMPLOYER

PROTECTED ACTIVITY IN AIR21 CASE; COMPLAINANT’S INTERNAL

REPORTING TO MANAGEMENT OF POTENTIAL FAA RULES VIOLATION MAY BE

SUFFICIENT AND THE FAA NEED NOT ALSO BE INFORMED

In Bondurant v. Southwest Airlines, Inc., ARB No. 14-049, ALJ No. 2013-AIR-7 (ARB Feb. 29,

2016), the ARB vacated the ALJ’s decision and order granting summary judgment in favor of the

Respondents in an AIR21 whistleblower case where a genuine issue of material fact existed that

precluded summary decision. The ALJ found that the Complainant may have had a reasonable

concern that the Respondent was failing to comply with a requirement to report shipping incidents

to the FAA, but that the Complainant must have communicated that concern and that the record

showed that the Complainant did not raise concerns about reporting until he was being discharged.

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The ARB determined that the ALJ erred in focusing on the lack of communication of the concerns.

The ARB wrote:

We hold that the ALJ unduly limited his consideration of protected activity to

whether Bondurant communicated to Respondent his reasonable belief that

Respondent was failing to report a FAA violation. The ALJ stated: “However, it is

not enough that a complainant honestly and reasonably believed there was or would

be a violation. He must also have communicated that concern and the essence of

Respondent’s Motion is that there is nothing in the record to allow a finding of fact

to decide that he did so.” This was error for two reasons. First, we have repeatedly

held that a complainant need not actually convey reasonable belief to his or her

employer’; “[t]he reasonable belief standard requires an examination of the

reasonableness of a complainant’s beliefs, but not whether the complainant actually

communicated the reasonableness of those beliefs to management or the

authorities.” Second, Bondurant presented evidence that on February 22, 2012, he

reported to upper management that Respondent had transported lithium batteries in

an unsafe manner. This is sufficient to raise a genuine issue of material fact with

respect to protected activity. Protection under the statute may be afforded to reports

of information relating to air carrier safety—a complainant need not also report the

air carrier’s failure to report such information to the FAA.

USDOL/OALJ Reporter at 5 (footnote omitted) (emphasis as in original).

NO PROTECTED ACTIVITY UNDER AIR21 WHERE EMPLOYEE OPPOSED

FEDERAL FLIGHT DECK OFFICER (FFDO) PROGRAM GENERALLY BUT DID NOT

DEMONSTRATE GOOD FAITH BELIEF THAT FLYING WITH FFDO PILOT WOULD

POSE SAFETY RISK

In Burdette v. ExpressJet Airlines, Inc., ARB No. 14-059, ALJ No. 2013-AIR-16 (ARB Jan. 21,

2016), the Complainant filed a complaint alleging that he was terminated from his position as a

pilot based on his protected activity of refusing to alternate flight legs with a Federal Flight Deck

Officer (FFDO), an individual authorized and trained to carry a firearm in aircraft cockpits to

defend against acts of criminal violence. The Complainant alleged that he felt unsafe flying in the

presence of an FFDO, and over the course of several years he engaged in a number of actions

indicating his opposition to the FFDO program, including sending complaint letters and refusing

to fly with FFDOs. These actions culminated in his being required to sign a “Last Change

Agreement” and being issued a warning letter from his employer. On the date of the alleged

protected activity, the Complainant was assigned to fly as co-pilot with an FFDO. After learning

that his request for a replacement pilot had not been granted, the Complainant designated the FFDO

to be the flying pilot for each flight leg of the multi-day trip, stating that the assignment was

necessary for him to safely manage the cockpit in the presence of the FFDO. After refusing the

on-call chief pilot’s request that he alternate flying legs of the trip with the FFDO, the Complainant

was terminated from his position.

The Board found that substantial evidence in the record supported the ALJ’s finding that the

Complainant failed to prove that he engaged in AIR21 protected activity. The Board agreed with

the ALJ that the Complainant did not demonstrate a good faith belief that flying with an FFDO

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would have been too great a distraction for him to fly safely, given that the Complainant testified

that his previous flights with FFDOs had been conducted safely and that he was not distracted as

a flying pilot on these flights. The Board stated that, while Complainant opposed the FFDO

program and believed it to be unsafe generally, his testimony indicated that he believed he could

fly safely with FFDOs. Further, the Board found that the Complainant put forth no evidence that

individuals with his training and experience would have believed that safety would have been a

risk had he acted as flying pilot.

PROTECTED ACTIVITY; COMPLAINANT NEED NOT ESTABLISH AN ACTUAL

VIOLATION WHERE THE REPORTED MATTER RELATED TO A VIOLATION OR

ALLEGED VIOLATION OF FAA REQUIREMENT OR OTHER FEDERAL LAW

RELATED TO AIR CARRIER SAFEETY, AND EMPLOYEE'S BELIEF OF VIOLATION

WAS SUBJECTIVELY AND OBJECTIVELY REASONABLE

PROTECTED ACTIVITY; RESPONDENT CANNOT "CURE" OR ERASE

PROTECTED ACTIVITY BY ADMITTING TO WRONGDOING, APOLOGIZING, OR

AGREEING WITH THE COMPLAINANT ABOUT A SAFETY CONCERN

PROTECTED ACTIVITY; FINDING THAT RESPONDENT DID NOT CONDONE

SAFETY PROBLEMS OR FAA VIOLATIONS IS NOT RELEVANT TO QUESTION

WHETHER COMPLAINANT ENGAGED IN PROTECTED ACTIVITY

PROTECTED ACTIVITY; AIR21 DOES NOT REQUIRE THAT PROTECTED

ACTIVITY RELATE "DEFINITELY AND SPECIFICALLY" TO A SAFETY ISSUE

In Sewade v. Halo-Flight, Inc., ARB No. 13-098, ALJ No. 2013-AIR-9 (ARB Feb. 13, 2015), the

Complainant was a helicopter pilot for the Respondent. The ALJ determined that the Complainant

had not engaged in protected activity, finding that none of the issues that the Complainant raised

involved safety issues or that the Respondent was "condoning" safety issues in violation of FAA

rules or regulations. Regarding a fuel system transfer light issue, the ALJ found that the aircraft's

safe operation was not involved, and that the Respondent's Director of Operations "cured any

alleged improper conduct" when he admitted wrongdoing and apologized for pressuring the

Complainant to fly when she was not comfortable doing so. Regarding an aircraft pitching issue,

the ALJ found that the problem did not involve an FAA violation. The ALJ did not address two

other allegations of protected activity by the Complainant.

The ARB reversed the ALJ's determination on the fuel system transfer light issue. The ARB wrote:

The ALJ incorrectly analyzed the issue whether Sewade engaged in protected

activity. First, an employee need not prove an actual FAA violation to satisfy the

protected activity requirement where (1) the employee's report or attempted report

is "related to a violation or alleged violation of an FAA requirement or any federal

law related to air carrier safety, and (2) the employee's belief of a violation is

subjectively and objectively reasonable." Second, an employer cannot "cure"

protected activity or erase that it occurred by admitting to wrongdoing, by

apologizing, or by agreeing with the employee about a safety concern. When an

employee makes a protected complaint, the employer's response (positive or

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negative) does not change that AIR 21 protected activity has occurred. Third,

finding protected activity does not depend on whether an employer "condoned"

safety problems or FAA violations as the ALJ seems to have required. Finally, the

AIR 21 whistleblower statute does not require that protected activity relate

"definitely and specifically" to a safety issue.

USDOL/OALJ Reporter at 8 (footnotes omitted). Reviewing the evidence of record, the ARB

found that the transfer lights were designed to indicate that the aircraft was ready to fly, but had

not been turning on consistently; that the Complainant was the pilot in command and did not feel

that the helicopter was safe to fly and had so reported; and that it was undisputed that the lights

were not working and that the Complainant had reported about them because she subjectively

believed that there was a safety violation. The ARB also found that the Director of Operations'

statement that there would be no violation of FAA rules or regulations for the Complainant to fly

the helicopter "once the fuel transfer lights [turned] on and off as expected" suggested that there

may have been a violation before the lights worked as expected. The ARB found that the

Complainant's report and refusal to fly were each protected activity under AIR21, even if the

Director of Operations agreed with the Complainant's concern and her decision not to fly unless

the lights came on. The ARB further found that the Director of Operations apology for pressuring

the Complainant to fly was additional evidence of the objective reasonableness of the

Complainant's belief about the safety issue. Thus, the ARB reversed the ALJ and found that the

record established that the Complainant's report of the faulty fuel transfer lights, and related refusal

to fly, were protected activity under AIR21.

The ARB remanded for further factfinding on the other alleged instances of protected activity.

PROTECTED ACTIVITY; FIRST OFFICER WHO HAD BEEN FAILED ON A CHECK

FLIGHT TEST AND STATED THAT HE WOULD GO TO THE FAA; "ABOUT TO

PROVIDE" LANGUAGE FROM THE STATUTE PROTECTS EMPLOYEES WHO

THREATEN TO FILE COMPLAINTS WITH FEDERAL AUTHORITIES; ALJ ERRED

IN FINDING STATEMENT WAS TOO VAGUE TO CONSTITUTE PROTECTED

ACTIVITY; ALL THAT IS REQUIRED IS THAT THE COMPLAINANT REASONABLY

BELIEVED THAT HE WAS ABOUT TO PROVIDE COVERED INFORMATION

REGARDLESS OF WHETHER HE CONVEYED HIS REASONABLE BELIEF TO HIS

EMPLOYER

In Occhione v. PSA Airlines, Inc., ARB No. 13-061, ALJ No. 2011-AIR-12 (ARB Nov. 26, 2014),

the Complainant was a first officer seeking to upgrade to captain. As part of the upgrading process,

a candidate must go through a "check ride" test in a simulator. Check rides are administered by

"Aircrew Program Designees" (ADP), who are pilots approved to act for the FAA. Check rides

must adhere to federal regulations and "Practical Test Standards" (PTS), and the FSIMS inspector's

handbook. If a first officer fails a first attempt to upgrade to captain, the FAA requires retraining

and rechecking before the candidate can return to work as a first officer. The candidate may make

a second attempt after six months. According to the applicable collective bargaining agreement, if

a first officer fails the second attempt, the company has discretion on how to deal with the situation.

The Respondent's policy is to terminate the first officer's employment or allow him to resign in

lieu of termination.

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The Complainant failed his first check ride, and informed the Respondent that he intended to

contact the FAA. The Complainant failed his second check ride but later re-qualified as a first

officer. The Complainant sent a letter to Respondent grieving how the check rides had been

administered, copying the letter on FAA officials. Months later, the Complainant submitted an

FAA Hotline complaint asserting that the check rides had not been administered in accordance

with the PTS. The FAA made inquiries.

The Complainant entered a new upgrade class. The Complainant was failed on his third and fourth

check ride attempts, and was therefore terminated from employment. The Complainant filed an

AIR21 complaint with DOL.

The ARB affirmed the ALJ's findings that the Complainant engaged in protected activity on

several occasions. The ALJ found, however, that the Complainant had not engaged in protected

activity when he merely informed officials with the Respondent that he was going to the FAA

because the statements failed to allege any specific safety violations and were vague. The ARB

reversed this finding. The ARB noted that AIR21 protects employees "about to provide"

information, and that such language in other whistleblower statutes had been interpreted as

protecting employees who threaten to file complaints with federal authorities regardless of whether

the employee has actually filed a complaint. The ARB recognized that the ALJ had relied on prior

ARB authority holding that complaints must be specific under AIR21 to be protected

(e.g., Simpson v. United Parcel Serv., ARB No. 06-065, ALJ No. 2005-AIR-31, slip op. at 5 (ARB

Mar. 14, 2008); Peck v. Safe Air Int'l, Inc., ARB No. 02-028, ALJ No. 2001-AIR-3, slip op. at 13

(ARB Jan. 30, 2004)), but stated that "more recent ARB precedent as well as Fourth Circuit law

leads us to conclude that this specificity standard is inappropriate and inconsistent with the AIR

21 whistleblower statute." USDOL/OALJ Reporter at 8 (footnote omitted). See Sylvester v.

Paraxel Int'l LLC, ARB No. 07-123, ALJ Nos. 2007-SOX-39, -42; slip op. at 17-19 (ARB May

25, 2011) ("reasonable belief standard requires an examination of the reasonableness of a

complainant's beliefs, but not whether the complainant actually communicated the reasonableness

of those beliefs to management or the authorities"); Knox v. U.S. Dep't of Labor, 434 F.3d 721,

725 (4th Cir. 2006) (inquiry into the "reasonable belief" of a complainant does not require that the

complainant convey his reasonable belief to management). The ARB concluded:

As long as [the Complainant] "reasonably believed" that he was "about to provide"

the FAA with "information relating to any violation or alleged violation of any

[FAA] order, regulation, or standard," his communications to [the ADP who

administered the check ride and the Director of Flight Standards] were protected

regardless of whether [the Complainant] conveyed his reasonable belief to his

employer. The relevant question is whether [the Complainant] reasonably believed

that the check ride [the ADP] administered violated an FAA standard when he told

both [the ADP and the Director of Flight Standards] that he was "going to the FAA."

USDOL/OALJ Reporter at 9. The ARB also determined that when the Complainant informed his

supervisors of his intent to go to the FAA, it would be logical to assume that it was for the same

reasons as specified in his protected communication from a month earlier.

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PROTECTED ACTIVITY; FACT THAT EMPLOYER AGREES WITH SAFETY

CONCERN DOES NOT NEGATE THE RAISING OF THE CONCERN AS PROTECTED

ACTIVITY

PROTECTED ACTIVITY; FACT THAT EMPLOYER GROUNDS A PLANE BASED ON

SAFETY CONCERN RAISED BY COMPLAINANT CONFIRMS THAT RAISING OF

COMPLAINT WAS REASONABLE

PROTECTED ACTIVITY; ATTEMPT TO TAPE RECORD MEETING TO DOCUMENT

RETALIATION UNDER AIR21 IS PROTECTED ACTIVITY

In Benjamin v. Citationshares Management, LLC, ARB No. 12-029, ALJ No. 2010-AIR-1 (ARB

Nov. 5, 2013), the Complainant was a pilot who flew passenger jets for CitationAir's private

clients. Prior to the beginning of a tour of duty, he saw the plane he was to fly being serviced and

undergoing a Continued Service Inspection. The mechanics confirmed in writing that the plane

passed inspection, including the landing gear struts. The next day, the Complainant observed a

problem with one of the landing gear struts, and the pilot in command agreed that it should be

reported. The Complainant contacted the Flight Duty Officer and was referred to the company's

Chief Pilot. The Chief Pilot advised on steps to bring the strut into compliance, but when those

were unsuccessful, agreed that the plane must be grounded. The Chief Pilot then instructed the

Flight Duty Officer to remove the Complainant from the flight and assign another pilot for the tour

of duty. CitationAir then summoned the Complainant for a face-to-face meeting at its headquarters

relating to the report of the landing gear strut. The next day the Complainant filed an Aviation

Safety Action Program (ASAP) report with CitationAir's Vice President of Safety alleging that

indirect pressure was being placed on pilots to keep planes flying, and that this was a dangerous

and unsafe situation. The Complainant, expecting to be fired, purchased a pocket-size audio

recorder. At the meeting, an HR employee was present, which confirmed for the Complainant that

he needed to record the meeting to protect himself. The meeting began with a discussion of the

wing strut incident. When the recorder noisily malfunctioned, the Complainant was asked by the

Chief Pilot why he was recording the meeting, to which the Complainant stated he was afraid the

Chief Pilot would yell at him. The Chief Pilot immediately had the Complainant turn in his

company key and ID card, and had him escorted from the building. Several days later the

Complainant received a termination letter. CitationAir subsequently denied the Complainant's

request to have the termination decision peer reviewed. The Complainant then filed an AIR21

complaint. Following a hearing, the ALJ concluded that the Complainant had not engaged in

protected activity. The ARB reversed that finding.

Report of landing gear strut concern -- fact that Respondent agreed with Complainant's safety

report did not negate the report as protected activity

The ALJ found that the grounding of the plane was not protected activity because everyone

concerned agreed that the plane had to be grounded. The ARB found that the ALJ focused too

narrowly on the grounding and overlooked the safety report regarding the landing gear strut. The

ARB stated that "The fact that management agrees with an employee's assessment and

communication of a safety concern does not alter the status of the communication as protected

activity under the Act, but rather is evidence that the employee's disclosure was objectively

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reasonable." USDOL/OALJ Reporter at 6. The ARB found that this report was protected activity

as a matter of law, even if CitationAir agreed with the concern and decided to ground the plane.

Filing of ASAP report -- fact that Respondent grounded the plane based on safety concern raised

by Complainant confirmed that Complainant's safety concerns were reasonable

The ALJ did not make an express ruling on whether the ASAP report was protected activity, but

the ARB found that it was protected activity as a matter of law because (1) it expressly raised

specific safety concerns about the landing gear strut incident, and (2) CitationAir's management

agreed that the plane needed to be grounded thereby confirming that the Complainant's safety

concerns were reasonable.

Attempting recording of meeting

The ALJ acknowledged that ARB authority holds that under the proper circumstances, the lawful

taping of conversations to obtain information about safety-related conversations is protected

activity and should not subject an employee to any adverse action. Hoffman v. NetJets Aviation,

Inc., ARB No. 09-021, ALJ No. 2007-AIR-7 (ARB Mar. 24, 2011). The ALJ, however, found that

the Complainant's attempted recording in the instant case was not protected activity because "such

a 'recording was not expected or intended to preserve evidence of a compromise of safety.'"

USDOL/OALJ Reporter at 8 (quoting ALJ's decision). The ARB disagreed. The ARB found that

protected activity under AIR21 includes an attempt to provide information of retaliation that

violates AIR21. Thus, if the Complainant held a reasonable belief of retaliation at the meeting he

was summoned to, then his attempted recording of such retaliation was protected activity. The

ARB stated: "The ALJ held that "the recording was not expected or intended to preserve evidence

of a compromise of safety." But the ALJ should have also considered whether [the Complainant]

had a subjectively and objectively reasonable belief that he would suffer unlawful whistleblower

retaliation at the meeting, including discipline, intimidation, threats, or coercion." USDOL/OALJ

Reporter at 8 (citation omitted). The ARB found that the ALJ had resolved all the material facts

on the issue, leaving only the legal question as to whether the attempted recording in this case was

protected activity. The ARB found that it could resolve the legal question without a remand to the

ALJ. The record showed that the Complainant held a reasonable belief that the purpose of the

meeting was to fire him. Moreover, the Complainant had filed his ASAP complaint alleging that

the CitationAir uses indirect pressure to avoid writing up maintenance issues, and reasonably

believed that the meeting would be such an instance. Thus, under the facts of the case, the ARB

found that the Complainant's attempt to record the "yelling" he expected was a protected attempt

to document the unlawful intimidation he raised in his ASAP.

PROTECTED ACTIVITY; WORK REFUSAL AND REITERATING SAME

COMPLAINTS AFTER EARLIER COMPLAINTS HAD BEEN SUFFICIENTLY

RESOLVED FOUND NOT TO BE OBJECTIVELY REASONABLE AND NOT

PROTECTED ACTIVITY UNDER AIR21

In Shactman v. Helicopters, Inc., ARB No. 11-049, ALJ No. 2010-AIR-4 (ARB Jan. 25, 2013),

the Complainant's protected whistleblower concerns all related to another pilot. The ALJ found

that the Respondent sufficiently addressed all of the Complainant's concerns, and that the

Complainant's subsequent refusal to fly with that other pilot was not objectively reasonable as that

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refusal rested entirely on the same complaints he had previously raised. Consequently, given the

Respondent's previous communications with the Complainant, the ALJ found that the

Complainant's refusal was unreasonable and not protected whistleblower activity. The

Complainant produced no evidence of any safety incidents involving the other pilot between the

date the Respondent had sufficiently addressed the prior concerns and the Complainant's

termination. The ALJ also found that the Complainant's FAA complaint during that gap of time

was objectively unreasonable and not protected activity because it merely repeated the previously

resolved complaints. The ALJ credited the Respondent's reasons for terminating the Complainant's

employment, including claims of misconduct and a "confrontational attitude and poor working

relationship with co-workers." The ALJ specifically found that the Complainant's safety

complaints had not factored into the decision to terminate his employment, and that the

Complainant failed to establish that any protected activity was a contributing factor in his

termination. The ARB found that substantial evidence supported the ALJ essential factual findings

and summarily affirmed the ALJ's Decision and Order dismissing the complaint.

PROTECTED ACTIVITY; COMPLAINT ABOUT CO-WORKER'S DRUG ABUSE

Where the work involves safety-sensitive functions, a complainant engages in protected activity

under the AIR21 whistleblower provision when complaining to management about a co-worker's

drug abuse on the job. FAA regulations contain extensive drug testing provisions and prohibitions

pertaining to illegal drug use by aviation industry workers who perform "safety-sensitive"

functions. Nagle v. Unified Turbines, Inc., ARB No. 11-004, ALJ No. 2009-AIR-24 (ARB Mar.

30, 2012).

PROTECTED ACTIVITY; LOGBOOK ENTRY IS PROTECTED ACTIVITY WHERE

COMPLAINANT ALSO DEMANDED A MECHANICAL INSPECTION BEFORE HE

WOULD PILOT THE PLANE

The ARB in Luder v. Continental Airlines, Inc., ARB No. 10-026, ALJ No. 2008-AIR-9 (ARB

Jan. 31, 2012), found that the ALJ properly found that the Complainant engaged in protected

activity when he wrote up in the aircraft logbook an incident of severe turbulence based on

information received from the prior flight crew, and demanded inspection of the aircraft before he

would pilot the plane. The ARB stated that although the logbook entry in and of itself may not

have constituted protected activity, the Complainant's actions forced the required mechanical

inspection following a situation involving severe turbulence. Thus, his actions were thus

distinguishable from Fabre v. Werner Enters., ARB No. 09-026, 2008-STA-010 (ARB Dec. 22,

2009), cited by the Respondent in which the ARB held that action taken as "an integral part of

compliance with the regulations," without more, does not constitute protected activity. The

Respondent had argued that the logbook entry was simply an integral part of compliance with the

regulations.

PROTECTED ACTIVITY; SUBJECTIVE AND OBJECTIVE BELIEF; CHECKING OFF

ON CREW MEMBER VERIFICATION LIST

In Blount v. Northwest Airlines, Inc., ARB No. 09-120, ALJ No. 2007-AIR-9 (ARB Oct. 24,

2011), the Complainant was a part-time probationary customer service agent. His mentor, who

was trying to provide the Complainant with the experience of being a lead gate agent, asked him

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to sign off on a crew verification list after she and another agent had checked in the crew members.

The Complainant refused because he had not seen any of the crew and had not verified their

identities personally. The Complainant continued to refuse even after a supervisor informed him

that signing off on the paperwork did not indicate that the he had checked each crew member

personally, but only that other agents had done so as evidenced by their initials next to each crew

member's name. Later, supervisors and a safety director met with the Complainant to try to get

him to understand the procedure, but after the Complainant insisted that it would be fraudulent for

him to check off the paperwork without personally checking the crew's identification, the

Complainant was discharged for insubordination. The Complainant then filed an AIR21

whistleblower complaint.

On appeal, the ARB found that verification of crew members' identities is on its face an air safety

concern, but that protected activity under AIR 21 has two elements: (1) the information the

complainant provides must involve a purported violation of a regulation, order, or standard relating

to air carrier safety, though the complainant need not prove an actual violation; and (2) the

complainant's subjective belief that a violation occurred must be objectively reasonable. The ARB

found that substantial evidence supported the ALJ's finding that while the Complainant firmly

believed that signing the crew list without verifying crew members' identities personally would

violate an FAA regulation, his belief was not objectively reasonable in light of the testimony of

his mentor, the person who had drafted the Respondent's policy on crew verification; the

Complainant's classroom trainer, and the customer service manager who fired the Complainant.

Consequently, the Complainant had not engaged in protected activity.

One member of the Board concurred with the result, but found that the problem was not that the

Complainant's actions were not objectively reasonable - the member finding that the Complainant

had an objectively rational basis for his confusion as a new trainee. The member stated that "I

believe it is a dangerous precedent to say that an initially objective reason for an airport security

concern loses its protected activity status because a team of veteran employees insists that a policy

does not say what it appears to say." USDOL/OALJ Reporter at 12 (footnote omitted). Rather, the

concurring member found that the Complainant did not have a subjectively reasonable belief that

a violation had occurred, having been more worried about personal liability than raising of a safety

concern.

PROTECTED ACTIVITY; PILOT'S OBLIGATION TO DEEM HIMSELF UNFIT FOR

FLIGHT BASED ON MEDICAL CONDITION; UNION REPRESENTATIVE'S

ADVOCACY THAT RESPONDENT'S POLICIES CONTRAVENED THE FEDERAL

AVIATION REGULATIONS

CLEAR AND CONVINCING EVIDENCE STANDARD; RESPONDENT COULD NOT

MEET STANDARD WHERE IT FAILED TO ESTABLISH THAT IT HAD A PREEXISTING POLICY OF REQUIRING MEDICAL DOCUMENTATION TO SUPPORT A

PILOT'S SICK LEAVE OR THAT THE PILOT HAD ADVANCE NOTICE OF SUCH A

REQUIREMENT

In Furland v. American Airlines, Inc., ARB Nos. 09-102, 10-130, ALJ No. 2008-AIR-11 (ARB

July 27, 2011), the Complainant, a pilot, had been counseled about the Respondent's belief that his

sick leave use was excessive. About six weeks later, on June 27, 2007, the Complainant took

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himself off a scheduled flight on sick leave due to gastrointestinal effects from airline food on a

prior flight. The next day the Employer advised the Complainant that if he did not provide a

doctor's note, he could be subjected to corrective action including reversal of his paid sick leave

to unpaid. [The parties disagreed about whether the Complainant had been previously informed of

the medical verification requirement; the ALJ found that the Complainant had not been so

previously informed.] A union representative then, on July 9, 2007, sent a letter to the Respondent

on the Complainant's behalf protesting the request for a medical note, and asserting that the request

for documentation was harassment and constituted unlawful "pilot pushing," i.e., pressuring a pilot

to fly when unfit in violation of the Federal Aviation Regulations (FARs). The letter further stated

that the Respondent had not told the Complainant that he would be under observation or that he

would be required to provide medical documentation for sick leave use.

Later the Complainant and his union representatives met with a company representative to discuss

the sick leave use on June 27, 2007, and the Complainant's failure to provide medical

documentation for that leave. The company representative stressed that the Complainant called in

sick after the Respondent warned him against calling in sick, while the union representative argued

that the Respondent's demand for medical documentation pressured the Complainant to fly when

he was sick, in violation of his legal obligations under the FARs. After the meeting, the Respondent

deducted the amount it had paid for the June 27th sick leave from a later paycheck. The

Complainant filed an AIR21 complaint.

Protected Activity

The ARB found that substantial evidence supported the ALJ's finding that the Complainant

engaged in protected activity when he complained through the July 9, 2007 union letter and at the

August 27, 2008 meeting that the Respondent's actions pressuring him to fly even when sick

contravened the FARs. The ARB also found that the Complainant's taking himself off the June 27,

2007 flight was protected activity. The ARB found that the Complainant reasonably exercised his

authority under the FARs in deeming himself unfit for flight based on his medical condition.

Contributing Factor and Clear and Convincing Evidence

The ARB found it abundantly clear that the Complainant proved that his protected activities

contributed to the decision to dock his pay. It also found that substantial evidence supported the

ALJ's finding that the Respondent failed to prove by clear and convincing evidence that it would

have deducted the paid sick leave amount from the Complainant's pay absent protected activity.

The ALJ had noted that the Respondent failed to present evidence of a company-wide policy

requiring pilots to present medical documentation to support requests for sick leave, and had found

that the Complainant had not been informed in the earlier counseling session that his future sick

leave requests would require medical documentation and prior approval. The ARB elaborated:

We agree with the ALJ that employers have a compelling business interest in

requiring proof that their employees' absences based on illness are legitimate.

However, without pilots having prior notice of such a requirement -- whether

through company policy requiring such proof or advance notice that such proof will

be required -- such a requirement can prove retaliatory in violation of AIR 21.

Indeed, had Furland had prior notice that medical documentation was required to

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support a request for sick leave, then the contributing factor behind the decision to

dock his pay might have been a failure to supply medical documentation and the

results in this case might be different. However, in light of the ALJ's findings that

Furland had no such prior notice, we find that the ALJ's conclusion that American

Airlines failed to prove by clear and convincing evidence that it would have docked

Furland's pay notwithstanding his protected activity is fully supported by the

substantial evidence of record and in accordance with applicable law.

USDOL/OALJ Reporter at 9-10.

PROTECTED ACTIVITY; REASONABLENESS OF BELIEF OF SAFETY VIOLATION;

FACT THAT EQUIPMENT IS DEFERRED UNDER THE AIRCRAFT'S MINIMUM

EQUIPMENT LIST DOES NOT NEGATE PILOT'S OVERALL RESPONSIBILITY FOR

SAFETY OF FLIGHT OPERATIONS; THAT RESPONSIBILITY INCLUDES THE

SAFETY OF PERSONNEL WHO ASSIST IN DEPLANING

In Sitts v. COMAIR, Inc., ARB No. 09-130, ALJ No. 2008-AIR-7 (ARB May 31, 2011), the

Complainant, a pilot, was terminated from employment with the Respondent after he reported a

malfunctioning passenger power door assist system that he believed affected aircraft safety, and

when the Respondent did not address the safety concern, refused to fly the plane. The inoperable

system appeared on the aircraft's Minimum Equipment List (MEL). An FAA regulation permits

operation of an aircraft under specified conditions with inoperative equipment on the MEL. The

door could be operated manually, but required ground crew who knew how to do safely. Improper

manual operation could result in injury to both the crew and the door.

The ARB first analyzed whether the Complainant reasonably believed that his report of the

inoperable system involved a violation of aircraft safety. The ARB found that FAA regulations

would lead a pilot to reasonably believe that he or she has direct responsibility for determining

whether an aircraft is in safe condition, and the duty to report such concerns. The ARB found

credible testimony in the record that the pilot's obligations over flight safety includes the moments

prior to takeoff, and the moments after landing and deplaning. Thus, the pilot's safety obligations

reasonably extend to the safety of the personnel who assist in deplaning. The ARB noted that the

Complainant's past experiences with inoperable passenger power door assist systems supported a

finding that his safety concerns were genuine. The Respondent contended that the pilot in

command regulations conflict with the MEL regulation and that MEL-deferrals should take

priority. The ARB found that ". . . these two regulations do not necessarily conflict. While the

MEL regulation authorizes pilots to fly aircraft with malfunctioning equipment, there is nothing

in the regulation requiring that pilots do so. Indeed, there is no language in the MEL regulation

mandating that aircraft with MEL-deferred equipment be flown. Rather, the MEL regulation

permits pilots to fly such aircraft by carving an exception to the general rule that "no person may

take off an aircraft with inoperative instruments or equipment installed unless" certain conditions

are met." USDOL/OALJ Reporter at 112 (emphasis as in original) (footnote omitted). The ARB

found that substantial evidence supported the ALJ's finding that the Complainant had an

objectively reasonable belief that flying an aircraft with a malfunctioning passenger power door

assist system, even though MEL-deferred, was unsafe. The ARB also agreed with the ALJ that the

Respondent's efforts to convince the Complainant that the working conditions were safe, were

insufficient to undermine the continuing reasonableness of the Complainant's safety concerns.

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Thus, the Complainant's subsequent decision not to fly the aircraft was reasonable and protected

activity under the AIR21 whistleblower provision.

PROTECTED ACTIVITY; TAPING OF CONVERSATIONS TO SUPPORT AIR21

CLAIM NOT PROTECTED WHERE THEY HAD BECOME INDISCRIMINATE AND

EXCESSIVE

In Hoffman v. NetJets Aviation, Inc., ARB No. 09-021, ALJ No. 2007-AIR-7 (ARB Mar. 24,

2011), the ARB affirmed the ALJ's finding that the Respondent placed the Complainant on paid

administrative leave because it was concerned that the Complainant was recording confidential

information and non-safety related conversations, rather than because of the protected activity of

gathering evidence of air safety violations and discovery for an ongoing AIR21 whistleblower

proceeding. The record established that the Complainant had made over 750 recordings, and the

Respondent had a reasonable belief that some of the recordings did not involve protected activity.

Moreover, there was evidence that the Respondent had been concerned about recordings of

confidential financial information, and had scaled back the amount of confidential information it

disclosed to employees. The Complainant admitted that he had recorded portions of meetings

during which the company's financial status and business strategy were discussed, and the evidence

established that at least 37 recordings were not related to safety concerns.

The ARB emphasized that the lawful taping of conversations to obtain information about safetyrelated conversations is protected activity and should not subject an employee to any adverse

action. Nonetheless it distinguished earlier decisions holding that tape recording to gather evidence

of activities that are protected under the whistleblower statutes is protected, on the ground that the

Complainant in the instant case had engaged in indiscriminate and excessive recording of topics

unrelated to air safety, including the company's business strategy and finances.

One member of the Board dissented on the ground that under the facts of the case, it was impossible

to separate legal from illegal motives. Thus, the dissenter would have proceeded to mixed motive

analysis and found the Respondent liable for illegally placing the Complainant on administrative

leave while the tapes were reviewed by the Employer. Because the Complainant had been paid

while on leave, and had only suffered negligible loss of flight time due to protected activity, the

dissenter would not have awarded damages. The dissenter, however, would have declared the

Respondent's recordation policy, as written, illegal as a means of affirmative relief.

PROTECTED ACTIVITY; LACK OF REASONABLE BELIEF OF AIR SAFETY

VIOLATION ONCE DETERMINATION MADE THAT SUSPICIOUS DEVICE WAS

FAA FLIGHT APPROVED; MERE WORDS DO NOT CREATE VIOLATION OF AIR

SAFETY REGULATIONS WHERE THERE WAS NO VIOLATION IN FACT

In Hindsman v. Delta Air Lines, Inc., ARB No. 09-023, ALJ No. 2008-AIR-13 (ARB June 30,

2010), the Complainant, a lead flight attendant, noticed, before departure of a flight, a suspicious

portable oxygen device. She asked the gate agent and captain about it. Both replied that they

thought that devices such as portable oxygen concentrators were allowed on board. A lead agent

told the Complainant that the Respondent would not delay the flight and that she would have to

decide whether to take the passengers who owned the device, or to deplane them. The Complainant

consulted a manual and determined that the device was approved for flight by the FAA. Upon

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being informed by another flight attendant that the device was FAA-approved, the caption told

that attendant to "shut the door and let's go." The flight left 8 minutes late. Two days later the

Complainant wrote to the Respondent's flight safety director to report the incident, alleging that

the Respondent was going to dispatch the flight before she found out that the device was flight

approved. Several months later the Complainant was discharged on grounds of excessive

absenteeism. The Complainant filed an AIR21 complaint.

The ALJ granted summary decision in favor of the Respondent on the ground that, although the

Complainant had been aggressively carrying out her duties to ensure safety, once she discovered

that the device was flight approved she could not have had a reasonable belief that flying with the

device on board violated air safety regulations, and therefore she had not engaged in protected

activity. The ARB agreed. On appeal the Complainant argued that her memo to the flight safety

director was protected activity. The ARB, however, found that the memo demonstrated that no

violation of air safety regulations occurred, and that according to the Complainant's own account

of the incident , she, the captain, and the flight attendant all knew that the device was acceptable

before the plane took off. The Complainant also argued that there had been a violation because

ground personnel put on-time departure over safety by attempting to dispatch the flight without

investigation of the device. The ARB agreed with the ALJ, however, that "mere words do not

create an FAA violation when the parties' actual conduct does not violate the FAA regulations."

USDOL/OALJ Reporter at 6, quoting ALJ decision at 6. Moreover, while the lead agent did say

that the flight would not be delayed, she also told the Complainant to decide whether the

passengers and the device or to deplane them; the Complainant chose to determine whether the

device was FAA-approved and did so.

PROTECTED ACTIVITY; PILOT'S AUTHORITY TO DECLARE HIMSELF AND HIS

CREW UNFIT TO FLY

In Douglas v. Skywest Airlines, Inc., ARB Nos. 08-070, 08-074, ALJ No. 2006-AIR-14 (ARB

Sept. 30, 2009), the ARB found that substantial evidence supported the ALJ's finding that the

Complainant engaged in protected activity when he declared himself and his crew unfit to fly, and

informed his supervisors. The ALJ found that the Complainant genuinely believed that he would

be violating air safety regulations if he flew, and that belief was objectively reasonable. In regard

to the fitness of the crew, the ALJ pointed to federal regulations conferring final authority and

responsibility on the pilot in control of the aircraft. Although the Employer argued that this ruling

would permit crewmembers to refuse assignments based on the mere speculation that they will not

get sufficient rest and might be unfit later when the flying is to take place, the ARB found that

substantial evidence supported the ALJ's finding that the Complainant was unfit at the time he so

declared. The Complainant had discomfort from a recent medical procedure, and had just endured

an arduous three-hour flight in inclement weather.

PROTECTED ACTIVITY; REQUIREMENT THAT COMPLAINANT REASONABLY

BELIEVE IN EXISTENCE OF VIOLATION RELATING TO AIR CARRIER SAFETY

In order to be protected under the whistleblower provision of AIR21, the complainant must

reasonably believe in the existence of a violation of a regulation, order, or standard relating to air

carrier safety. Once an employee's concerns are addressed and resolved, it is no longer reasonable

for the employee to continue claiming a safety violation. In Malmanger v. Air Evac EMS, Inc.,

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ARB No. 08-071, ALJ No. 2007-AIR-8 (ARB July 2, 2009), the Complainant alleged three

instances of protected activity. The ARB, however, agreed with the ALJ that none of the instances

were based on a "reasonable belief" that the Respondent had violated any provision of Federal law

relating to air safety.

First, the Complainant had sent an e-mail to the Respondent's CEO and Board of Directors alleging

that several years before, a friend of the CEO had taken a joyride in one the Respondent's

helicopters and had returned the helicopter in an unairworthy condition, and that the CEO had

caused pressure to be put on the Complainant - a regional mechanic - to keep his mouth shut about

the incident. The "joyriding" incident had occurred years before, and the e-mail had been sent

shortly before a scheduled evaluation of the Complainant. The Complainant anticipated that the

evaluation process would be used to get rid of him. The ARB found that the e-mail was not

protected activity because when the Complainant sent the e-mail, he knew that his concerns about

the joyriding incident had been resolved. The Complainant himself had signed off on the safety of

the helicopter before it was returned to service, and had never raised concerns relevant to this issue

in the three years that elapsed before he sent his e-mail.

Second, the Complainant did not demonstrate that he reasonably believed that another mechanic

had violated an air safety rule when the two disagreed about which maintenance manual was

applicable to determine whether a tail rotor assembly was out of limits. The matter had been

resolved because the Complainant had ignored the other mechanic's advice and changed the rotor

assembly. Moreover, the Complainant did not pinpoint an air safety violation.

Third, the Complainant did not reasonably believe that a supervisor had violated an air safety rule

when he allowed a base mechanic to keep a helicopter in service pending delivery of a new oil

tank. By the time the Complainant complained to management, he knew that the oil tank had been

replaced, and it was no longer reasonable for the Complainant to continue claiming a safety

violation.

Finally, the Complainant argued that the ALJ improperly relied on the Complainant's motivation

for the complaints (the ALJ finding that the complaints were made to forestall a probable adverse

performance evaluation). The ARB agreed with the proposition that there is no requirement that a

whistleblower's actions be motivated by safety concerns. Nonetheless, the ARB found that the

ALJ's finding that the Complainant "was insincere [was] a finding that [the Complainant] did not

actually believe that violations existed at the time he made his complaints."

PROTECTED ACTIVITY; COMPLAINANT'S LACK OF REASONABLE BELIEF IN

VERACITY OF ALLEGATION

CONTRIBUTING CAUSE; EVIDENCE THAT SOLE MOTIVATING FACTOR WAS

FALSE ALLEGATION MADE BY COMPLAINANT

In Walker v. USDOL, No. 07-72072 (9th Cir. Dec. 4, 2008) (unpublished) (case below ARB No.

05-028, ALJ No. 2003-AIR-17), the Ninth Circuit found that the ARB did not err in affirming the

ALJ's finding that the Complainant had not engaged in protected activity when he called the

company employee hotline to make an allegation against three supervisors where the allegation

was false and the Complainant did not have a reasonable belief in its veracity. While the

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Complainant may have engaged in other protected activity, the ARB did not err in concluding that

substantial evidence supported the ALJ's finding that the falsehood solely motivated the

termination.

PROTECTED ACTIVITY; MUST RELATE TO A REGULATION OR ORDER, MUST

BE SPECIFIC, AND MUST BE REASONABLY BELIEVED BY THE COMPLAINANT

To constitute protected activity under AIR21, a complainant's complaints must relate to a

regulation or order, must be specific, and must be reasonably believed by the complainant.

In Simpson v. United Parcel Service, ARB No. 06-065, ALJ No. 2005-AIR-31 (ARB Mar. 14,

2008), one of the Respondent's aircraft was taken out of service to correct a problem with the cabin

pressurization system. After the Complainant and a co-worker reported that the system had been

fixed, and signed the logbook to confirm the correction, the Complainant was found still working

in the cockpit. She explained that there had been too many deferrals with that aircraft, and that

something was "illegal." According to an acting supervisor, when pressed to explain, the

Complainant did not point to anything in particular but just stated that something didn't feel right.

The ARB held that this was not protected activity because the Complainant (1) was never able to

indicate to any supervisor a concern related to a violation of any safety regulation or order other

than the pressurization system problem which had already been corrected, (2) failed to

communicate any specific safety defect that her employer could take corrective action on, and (3)

did not demonstrate a reasonable belief that a violation of an air safety regulation or order existed

given that she had signed off on the logbook.

PROTECTED ACTIVITY; MERELY PERFORMING SAFETY-RELATED DUTIES,

STANDING ALONE, DOES NOT CONSTITUTE PROTECTED ACTIVITY

A maintenance supervisor's carrying out of his required, safety-related duties -- supervising the

maintenance of the Respondent's aircraft and reporting, repairing, or deferring the repair of any

documented defects -- is not, standing alone, protected activity under AIR21. Rather, to be

protected, the employee must provide information to the employer or to the federal government

that relates FAA orders, regulations or standards, or other provision of law related to air carrier

safety. While laudable, competently and aggressively carrying out duties to ensure safety does not,

standing alone, constitute protected activity. Thus, in Sievers v. Alaska Airlines, Inc., ARB No.

05-109, ALJ No. 2004-AIR-28 (ARB Jan. 30, 2008), the ARB found that the Complainant did not

engage in protected activity regarding incidents in which information was not provided to the

employer or to a Federal entity, but that he did engage in protected activity when he refused to

override a maintenance crew's decision to take a plane out of service because it would have been

"wrong" (i.e., it would have violated the FAA rule at 14 C.F.R. § 135.443).

PROTECTED ACTIVITY; FILING OF DISCOVERY IN A PRIOR WHISTLEBLOWER

PROCEEDING

In Powers v. Paper, Allied-Industrial Chemical & Energy Workers Int'l Union (PACE), ARB

No. 04-111, ALJ No. 2004-AIR-19 (ARB Aug. 31, 2007), the ALJ erred in concluding that serving

a discovery request could not constitute protected activity. The ARB held that "it is possible that

serving a discovery request potentially could constitute protected activity if the request was part

of a whistleblower complaint." Slip op. at 10 (footnote omitted).

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PROTECTED ACTIVITY; UNDER AIR21, THE PROVISION OF INFORMATION

ABOUT SAFETY IS PROTECTED ONLY WHEN THE COMPLAINANT ACTUALLY

BELIEVES IN THE EXISTENCE OF A VIOLATION

In Walker v. American Airlines, Inc., ARB No. 05-028, ALJ No. 2003-AIR-17 (ARB Mar. 30,

2007), the Complainant, a level 4 maintenance supervisor, made a call to the Respondent's hotline

primarily complaining about a change in policy regarding how overtime work would be credited,

but also including a statement charging that several higher level supervisors had been intimidating

the Complainant into signing off on tasks that had not been completed or were not safe just so they

could get the plane out. The Complainant later signed a statement retracting the charge that the

supervisors had been intimidating him. Following a hearing, the ALJ found that the Complainant

had not had a good faith and reasonable basis for making the allegation about supervisor pressure

to sign off on items. The ALJ's finding was largely based on credibility determinations, which the

Complainant challenged on appeal, but which the ARB found were supported by substantial

evidence. The ARB also affirmed the ALJ's finding that the hotline call was not protected activity

because it was not made in good faith. Assuming for purposes of argument that the hotline call

implicated safety, the ARB held that the provision of information is protected activity only when

the complainant actually believes in the existence of a violation.

PROTECTED ACTIVITY; COMPLAINANT'S REASONABLE BELIEF THAT FLYING

WITH A FATIGUED CREW WOULD VIOLATE A FEDERAL AVIATION

REGULATION

In Rooks v. Planet Airways, Inc., ARB No. 04-092, ALJ No. 2003-AIR-35 (ARB June 28, 2006),

the ARB affirmed the ALJ's finding that the Complainant engaged in protected activity when he

refused to complete a delayed flight because the flight crew was fatigued, and the Complainant

believed that flying with a fatigued crew was a hazard covered by the federal aviation regulation

("FAR") at 14 C.F.R. § 121.553. The ARB noted that the Complainant did not have to prove that

flying with fatigued crew members actually violated the FARs, as long as his belief that it did was

reasonable.

PROTECTED ACTIVITY; GENUINE BELIEF IN VIOLATION OF FEDERAL AIR

CARRIER SAFETY LAW; OBJECTIVE REASONABLENESS OF BELIEF;

SPECIFICITY OF CONCERN

In Rougas v. Southeast Airlines, Inc., ARB No. 04-139, ALJ No. 2004-AIR-3 (ARB July 31,

2006), the ARB remanded to the ALJ for further fact finding where the ALJ had overlooked

several circumstances alleged by the Complainant in his post-hearing brief to constitute protected

activity. The ARB instructed that the ALJ only needed to look at the activities that the Complainant

raised in the post-hearing brief because arguments made for the first time on appeal are waived.

The ARB also instructed the ALJ that the governing law for determining whether an activity is

protected under AIR21 requires findings on whether:

•

•

the complainant genuinely believed that there was or would be a violation or

alleged violation of an FAA order, regulation or standard, or a Federal law

relating to air carrier safety

the concern was objectively reasonable in the circumstances, and

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•

the complainant expressed his concern "in a manner that was 'specific' with

respect to the 'practice, condition, directive or event' giving rise to the concern."

Slip op. at 14.

PROTECTED ACTIVITY;

DISCRIMINATION

PRETEXTUAL

REASON

AS

EVIDENCE

OF

In Lebo v. Piedmont-Hawthorne, ARB No. 04-020, ALJ No. 2003-AIR-25 (ARB Aug. 30, 2005),

where the evidence established that the Respondent's stated reason for discharging the

Complainant -- that it discovered that the Complainant's work was much worse that it first

suspected when it suspended him -- was pretext, the ARB found such pretext was evidence of

discrimination.

PROTECTED ACTIVITY; CARRYING OUT AGGRESSIVE AND COMPETENT

INSPECTIONS REQUIRED OF A MAINTENANCE SUPERVISOR; SUCH ACTIVITIES

DO NOT REQUIRE A FORMAL COMPLAINT TO THE FAA OR A COMPANY HOTLINE TO BE PROTECTED

In Sievers v. Alaska Airlines Inc., 2004-AIR-28 (ALJ May 23, 2005), the ALJ found that the

Complainant, an aviation line maintenance supervisor, engaged in protected activity when he

carried out his required, safety-related duties competently and aggressively, even though some of

the defects identified by the Complainant and his staff did not implicate serious safety

concerns. Mackowiak v. Univ. Nuclear Sys. Inc., 735 F.2d 1159, 1163 (9th Cir. 1984); Kinser v.

Mesaba Aviation, Inc., 2003-AIR-7 (ALJ Feb. 9, 2004), at 23; Szpyrka v. American Eagle Airlines,

Inc., 2002-AIR-9 (ALJ July 8, 2002). The ALJ rejected the Respondent's argument that inspection

duties were not protected activity because they did not involve a complaint to the FAA or the

Respondent's safety "hot line." The ALJ wrote: "For a finding of protected activity, it is sufficient

that Complainant carried out his required, safety-related duties: supervising the maintenance of

Respondent's aircraft and reporting, repairing, or deferring the repair of any documented defects."

Slip op. at 24. The ALJ observed that the Complainant's aggressive performance of his duties was

not conducted out of malice, but in an atmosphere of concern over the appropriate balance between

safety and economics given a tragic crash of one of the Respondent's flights in January of 2000.

The crash was linked to a maintenance issue. Moreover, the Respondent had commissioned a

report on its safety procedures in the wake of that crash; the report warned care must be take not

to permit economic pressures on the aviation industry to allow a "culture creep" away from an

emphasis on safety. These circumstances were well known to the Complainant and his staff.

PROTECTED ACTIVITY; REPORT OF BELIEF OF EXPOSURE TO PESTICIDE

SPRAYING MANDATED BY FOREIGN GOVERNMENTS, BUT NOT SUBJECT TO

ANY LAW OF THE U.S., IS NOT PROTECTED ACTIVITY WITHIN THE MEANING

OF THE WHISTLEBLOWER PROVISION OF AIR21

In Mehan v. Delta Air Lines, ARB No. 03-070. ALJ No. 2003-AIR-4 (ARB Feb. 24, 2005), the

ARB granted summary judgment in favor of the Respondent because the Complainant had failed

to articulate a viable factual basis for her claim that she had engaged in protected activity.

Specifically, the Board wrote: "Reporting to Delta her belief that she had been injured by pesticide

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spraying that was mandated by foreign governments, but that was not subject to any law of the

United States, does not fall within the plain language of § 42121 -- providing information or filing

a proceeding relating to a violation of Federal air carrier safety laws."

PROTECTED ACTIVITY; COMPLAINTS ABOUT CALL SIGNS AND COMMERCIAL

ACTIVITIES

In Barker v. Ameristar Airlines, Inc., 2004-AIR-12 (ALJ Oct. 7, 2004), the ALJ found that the

Complainant's complaints about the Respondent's use of an affiliated company's call signs and its

alleged commercial transactions outside the scope of its Part 125 certification were not protected

activity because neither allegation related to air carrier safety.

PROTECTED ACTIVITY; PARTICIPATION IN INVESTIGATION OF ACTIVITY

REASONABLY PERCEIVED TO BE IN VIOLATION OF FAA REGULATIONS

In Hendrix v. American Airlines, Inc., 2004-AIR-10, 2004-SOX-23 (ALJ Dec. 9, 2003), the ALJ

found that the Complainant engaged in protected activity under the AIR21 when he participated

in the investigation of an employee who was creating art objects out of company material where

the Complainant had the reasonable belief that FAA regulations on the disposal of scrap aircraft

parts were not being following. There was no dispute that the manager who initiated the

investigation reported specific violations. Thus, even if the Complainant himself did not articulate

specific violations, his conduct was protected activity because he was assisting that manager in the

investigation, and the AIR21 protects employees who provide or "cause to be provided"

information relating to the relevant violations.

PROTECTED ACTIVITY;

REASONABLE BASIS

HOTLINE

COMPLAINT

MADE

WITHOUT

A

In Walker v. American Airlines, 2003-AIR-17 (ALJ Nov. 16, 2004), the ALJ found that the

Complainant was not engaged in protected activity when he made a call to the company hotline.

The ALJ found that the evidence showed that although the Complainant might have had a good

faith belief and reasonable basis for making a hotline complaint about understaffing and deadline

pressures, the complaint he actually lodged -- alleging that managers were intimidating him into

signing off on tasks that they knew had not been completed or were not safe just so they could get

planes off the ground -- was not grounded in good faith or a reasonable belief. The ALJ recognized

that the distinction may not seem great, but it was the difference between accusing managers of

unknowingly causing safety problems by pushing too hard and intentionally disregarding known

safety problems.

PROTECTED ACTIVITY; THREE ELEMENTS; REGISTERING OF COMPLAINT

WITH LOCAL AUTHORITIES FOLLOWING CONSULTATION WITH FEDERAL

AUTHORITY

In Svendsen v. Air Methods, Inc., ARB No. 03-074, 2002-AIR-16 (ARB Aug. 26, 2004), the ARB

adopted the ALJ's finding that the Complainant was engaged in protected activity when he reported

a dust cloud near the airport at which he was assigned for air ambulance flights. The dust cloud

had been produced by a car race organized by a local Indian tribe, and the Complainant feared that

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it reduced visibility, especially for incoming flights. In the ALJ's decision, he found that "a

protected activity under AIR 21 has three elements. First, the complaint must either: a) involve a

purported violation of an FAA regulation, standard or order relating to air carrier safety, or any

other provision of Federal law relating to air carrier safety; or, b) at least "touch on" air carrier

safety. Second, the complainant's belief about the purported violation must be objectively

reasonable. Third, the complaint must be made either to the complainant's employer or the Federal

Government." Svendsen v. Air Methods, Inc., 2002-AIR-16 (ALJ Mar. 3, 2003), slip op. at 48.

The ALJ found that the complaint touched on air carrier safety and represented an objectively

reasonable flight safety hazard. Id. at 49. The ALJ noted that the Complainant registered his

complaint with the local tribe police and government, which were neither the Federal government

nor the Complainant's employer. The Complainant had done so, however, after first reporting the

visibility issue to a Federal flight service station, which concluded that it did not have the ability

to act on the complaint and directed the Complainant to local authorities.

PROTECTED ACTIVITY; ALLEGED

DEFINITIVELY AND SPECIFICALLY

ACT

MUST

IMPLICATE

SAFETY

In Fader v. Transportation Security Administration, 2004-AIR-27 (ALJ June 17, 2004), the

Complainant's AIR21 complaint stated only that he had reported violations of the Privacy Act,

abuses of the junior workforce, nepotism and fraud. The ALJ, citing caselaw to the effect that

protected activity under AIR21 must raise safety definitively and specifically, granted the

Respondent's motion to dismiss for failure to state claim upon which relief can be granted.

PROTECTED ACTIVITY; PENDING FAA REGULATION

In Weil v. Planet Airways, Inc., 2003-AIR-18 (ALJ Mar. 16, 2004), the ALJ found that the

Complainant engaged in protected activity when he forcefully advocated for implementation of

the Advanced Passenger Information System (APIS) imposed after September 11 to obtain and

monitor information about people entering the United States. The ALJ found that a protected

activity under AIR21 has three components: "First, the report or action must involve a purported

violation of a Federal law or FAA regulation, standard or order relating to air carrier safety and at

least 'touch on' air carrier safety. Second, the complainant's belief about the purported violation

must be objectively reasonable. Third, the complainant must communicate his safety concern to

either his employer or the Federal Government (49 U.S.C. § 42121 (a) (1))."

At the time the Complainant engaged in his advocacy on APIS, the FAA had only announced the

intention to implement such a system. The ALJ, however, found that an APIS rule was "imminent"

and that given that whistleblower laws are to be given a broad interpretation, found that the

Complainant met the first component of protected activity under AIR21. The ALJ found that the

Complainant had a reasonable concern that the Respondent would not meet the APIS compliance

deadline, and that he had clearly communicated that concern to Respondent's management. The

Complainant, however, was ultimately found by the ALJ not to be entitled to relief under the

AIR21 whistleblower provision because he was unable to prove that his protected activity

contributed to his termination from employment.

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PROTECTED ACTIVITY; MUST BE SPECIFIC IN RELATION TO GIVEN PRACTICE,

CONDITION, DIRECTIVE OR EVENT; COMPLAINANT MUST REASONABLY

BELIEVE IN EXISTENCE OF VIOLATION

In Peck v. Safe Air International, Inc., ARB No. 02-028, ALJ No. 2001-AIR-3 (ARB Jan. 30,

2004), the ARB described protected activity under the whistleblower provision of AIR21 as

follows:

Air carriers are prohibited under AIR21 section 519 from discharging or otherwise

discriminating against any employee because the employee, inter alia, provided the

employer or Federal Government with information "relating to any violation or

alleged violation of any order, regulation, or standard of the [FAA] or any other

provision of Federal law relating to air carrier safety . . . ." 49 U.S.C.A. § 42121(a).

While they may be oral or in writing, protected complaints must be specific in

relation to a given practice, condition, directive or event. A complainant reasonably

must believe in the existence of a violation. Clean Harbors Envtl. Serv. v. Herman,

146 F.3d 12, 19-21 (1st Cir. 1998); Leach v. Basin 3Western, Inc., ALJ No. 02STA-5, ARB No. 02-089, slip op. at 3 (ARB July 21, 2003).

PROTECTED ACTIVITY; PERFORMING DUTIES AS A QUALITY CONTROL

INSPECTOR INHERENTLY INVOLVE PROTECTED ACTIVITY

In Kinser v. Mesaba Aviation, Inc., 2003-AIR-7 (ALJ Feb. 9, 2004), the Respondent maintained

that the Complainant's reporting of damaged and missing bin latch shrouds did not constitute

protected activity because such did not implicate safety. The ALJ agreed that the record tended to

show that broken or missing shrouds did not implicate a serious safety concern, but nonetheless

found the Complainant, as a quality control inspector, was engaged in protected activity when he

reported the damaged or missing bin latch shrouds, citing Mackowiak v. University Nuclear

Systems, Inc., 735 F.2d 1159 (9th Cir. 1984) and Richter v. Baldwin Associates, 1984-ERA-9

(Sec'y Mar. 12, 1986), and FAA regulations imposing a duty on inspectors to report such

discrepancies.

PROTECTED ACTIVITY; WORK REFUSAL; REASONABLE BELIEF THAT WORK

ASKED TO BE PERFORMED WOULD VIOLATE FAA REGULATIONS OR QUALITY

CONTROL PROCEDURES

In Kinser v. Mesaba Aviation, Inc., 2003-AIR-7 (ALJ Feb. 9, 2004), the Complainant alleged that

his refusals to sign off on several C-checks were protected activity. The ALJ observed that AIR21

does not specifically list a refusal as protected activity, whereas section 5851 of the ERA does.

The ALJ found, however, that caselaw in existence prior to the amendment of the ERA to expressly

include work refusals as protected activity nonetheless categorized refusals as such. Durham v.

Georgia Power Co., 1986-ERA-9 (ALJ Oct. 24, 1986). Thus, the ALJ found that if the

Complainant's "refusal was based on a reasonable belief that he was being asked to violate FAA

regulations and quality control procedures by signing off on the C-check, his actions could

represent instituting proceedings under AIR21." The ALJ, however, ultimately found that the

Complainant did not have a reasonable belief that signing off on the checks would violate the law,

and therefore there refusals were not protected activity.

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PROTECTED ACTIVITY; FILING A WHISTLEBLOWER COMPLAINT

Filing a complaint or charge of employer retaliation because of safety and quality control activities

is protected activity under 49 U.S.C. § 42121(a)(1)-(4) (2002). Kinser v. Mesaba Aviation, Inc.,

2003-AIR-7 (ALJ Feb. 9, 2004).

PROTECTED ACTIVITY; OBJECTIVELY REASONABLE BELIEF OF VIOLATION

OF FAA REGULATION OR OTHER AVIATION LAW

In Parshley v. America West Airlines, 2002-AIR-10 (ALJ Aug. 5, 2002), the ALJ reviewed the

principles developed in environmental whistleblower cases, and found that a protected activity

under AIR 21 similarly has two elements: (1) the complaint must involve a purported violation of

an FAA regulation, standard or order relating to air carrier safety, or any other provision of Federal

law relating to air carrier safety; (2) the complainant's belief about the purported violation must be

objectively reasonable.

The ALJ noted that there is a caselaw mandate to broadly interpret the meaning of protected

activity. The ALJ nonetheless concluded that Complainant's reporting to her supervisor that she

had received a report that an individual had made improper computer entries indicating the

completion of an inspection step for 800 incoming aircraft parts, without verifying completion of

an inspection for documenting serviceability, was not protected activity. The ALJ found that this

was not protected activity because Complainant had failed to identify any FAA regulation or

aviation statute that requires such a computer inventory system. The ALJ was unwilling to drawn

an inference that such a process was required for FAA mandated inspections and certifications.

The ALJ, however, did find that Complainant engaged in protected activity when she reported to

her supervisor that some aircraft parts in the warehouse did not have an FAA- required serviceable

tag, based on credible testimony that such tags were required by the FAA.

PROTECTED ACTIVITY; MAINTAINING AIRCRAFT MAINTENANCE LOGS

In Szpyrka v. American Eagle Airlines, Inc., 2002-AIR-9 (ALJ July 8, 2002), Complainant

alleged that Respondent reprimanded and suspended him in retaliation for recording safety-related

mechanical deficiencies in aircraft maintenance logs causing the removal of aircraft from

passenger transport service and necessitating costly repairs. Respondent alleged that Complainant

was disciplined for purposely waiting to make those records in locations where Respondent would

have to pay a contractor rather than Respondent's own mechanics to make any needed repairs, at

a greater cost to Respondent, for the purpose of voicing his dislike of the company.

Respondent filed a motion for summary decision based, inter alia, on the argument that mere entry

of observations in aircraft maintenance logs does not, in and of itself, constitute either violations

of federal regulations or a "proceeding" within the meaning of AIR21. The ALJ declined to grant

summary decision on this basis, finding:

To be sure, it is not the existence of the pre-flight discrepancy which constitutes a

violation, and a crew member's notation in a maintenance log is not a proceedings.

Yet, an attempt to retaliate for, interfere with, or improperly influence the

performance of a duty required by the FAR may trigger the protections of AIR 21.

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46

Consequently, if an airline seeks retribution against an aircrew member for

performing required safety-related missions or if it engages in harassment,

intimidation, or coercion in an attempt to interfere with an aircrew member's duty

in the future, honestly and objectively, to carry out pre-flight inspection and

reporting obligations, the airline's action may implicate the broad, remedial

protections afforded by AIR 21. Since the circumstances which may constitute such

interference are fact-specific, summary decision would be inappropriate.

PROTECTED ACTIVITY; MAINTAINING AIRCRAFT MAINTENANCE LOGS;

OBJECTIVELY REASONABLE PERCEPTION STANDARD

In Davis v. United Airlines, Inc., 2001-AIR-5 (ALJ July 25, 2002), the ALJ applied ERA

whistleblower caselaw to find that a report of any objectively reasonable perceived violation of

federal laws or standards relating to air carrier safety is protected activity, even if the allegation is

not ultimately substantiated.

PROTECTED ACTIVITY; COMPLAINANT'S MOTIVE MAY INFLUENCE WHETHER

CONDUCT WAS PROTECTED

In Szpyrka v. American Eagle Airlines, Inc., 2002-AIR-9 (ALJ July 8, 2002), Complainant

alleged that Respondent reprimanded and suspended him in retaliation for recording safety-related

mechanical deficiencies in aircraft maintenance logs causing the removal of aircraft from

passenger transport service and necessitating costly repairs. Respondent alleged that Complainant

was disciplined for purposely waiting to make those records in locations where Respondent would

have to pay a contractor rather than Respondent's own mechanics to make any needed repairs, at

a greater cost to Respondent, for the purpose of voicing his dislike of the company.

Complainant filed a motion for summary decision, arguing that, even if he acted maliciously,

AIR21 protects behavior (the pre-flight inspection) that was a contributing factor in the

unfavorable personnel action. The ALJ declined to grant summary decision, finding that although

AIR21 might impose a lightened burden in establishing a prima facie case, the caselaw suggests

that the circumstances of the case necessitate a fact-dependent inquiry focusing on the true

impulses motivating the employee's actions, citing Zurenda v. J&K Plumbing & Heating Co. Inc.,

1997-STA-16 (ARB June 12, 1998).

PROTECTED ACTIVITY; COMPLAINTS MADE TO EMPLOYEES WITHOUT

CONTROL OVER COMPLAINANT'S EMPLOYMENT; COMPLAINTS TAKEN TO

THE PILOT DESPITE AINTENANCE SUPERVISOR'S CONCLUSION THAT THE

AIRCRAFT WAS FLIGHT WORTHY

In Davis v. United Airlines, Inc., 2001-AIR-5 (ALJ July 25, 2002), the ALJ rejected Respondent's

contention that complaints which touch on aircraft safety made internally to those without control

over the complainant's employment are not protected activities. The ALJ held that the established

law is that even complaints to co-workers as well as "informal" complaints to supervisors can be

protected activities and that the form of the "complaint" is not critical. The ALJ held that at the

point where on-duty maintenance supervisors and the pilots were informed by Complainant of

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47

potential safety defects, the reports became protected activity -- the ALJ finding that both the

supervisors and pilots were in a position to act on safety related complaints.

The ALJ also held that "[e]ven though United might believe supervisors may be better at balancing

the potential for delay versus a repair requirement, the broad purpose of the Act would best be

served by protecting mechanics, particul

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