RIPE, RIPER, RIPEST? THE NINTH CIRCUIT'S DECISION IN ADDINGTON V. U.S. AIRLINE PILOTS ASSOCIATION SETS A MISGUIDED RIPENESS STANDARD FOR DUTY OF FAIR REPRESENTATION CLAIMS.

The article presents a court case wherein the plaintiffs accused the defendant of breaching the duty of fair-representation (DFR) by negotiating a contract that favored them. The transition agreement (TA) between U.S. Airways Inc. and America West Airlines (AWA) raised a DFR claim by the union's west pilot against the east pilots. The Ninth Circuit held that the DFR claim against the union was not ripe before the ratification of a collective bargaining agreement (CBA) with the airlines.