This Note contends that the RLA prohibits due process review and further argues that such a result is constitutional. Part I examines the statutory language of the RLA itself and contends that it limits district court review to the three statutory grounds. Part II argues that the Supreme Court's opinion in Sheehan reaffirms this interpretation because the Court's language unmistakably conveys an intent to bar due process review. Part III explains that such a limitation does not violate the Constitution. The only constitutional provision that could be implicated in an RLA proceeding, the right of procedural due process, is protected by procedures mandated by the RLA. Finally, Part IV argues that this interpretation is desirable because it satisfies the needs of the railroad and airline industries.
Christopher L. Sagers,
Due Process Review Under the Railway Labor Act,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol94/iss2/7