Federal Court Rules Brightline's CRISI Grant Funding Subjects Intrastate Florida Railroad to Railway Labor Act

The dispute arose after the Transport Workers Union of America, AFL-CIO filed a representation application with the National Mediation Board in August 2024, seeking an election among Brightline's On-Board Service Employees, which include train and service attendants, chefs, and culinary specialists. Brightline challenged the NMB's authority to act, arguing that because the STB had previously determined it lacked jurisdiction over Brightline's purely intrastate Florida operations — the Miami-to-Orlando corridor — Brightline could not qualify as a "carrier" under the RLA and was therefore outside the NMB's reach.

Judge Darrin P. Gayles of the Southern District of Florida rejected that argument on two independent grounds. First, the court held that the RLA's definition of "carrier" in 45 U.S.C. § 151, First, uses the word "includes" when listing STB-regulated railroads, signaling a non-exhaustive list rather than a closed definition. Because intrastate railways are not among the entities the statute expressly excludes, Brightline's lack of STB oversight does not automatically place it outside RLA jurisdiction.

Second, and more consequentially, the court held that 49 U.S.C. § 22905(b) independently brings Brightline within the RLA. That provision states that any person conducting rail operations over infrastructure constructed or improved with CRISI grant funding "shall be considered a rail carrier" for purposes of the RLA and other enumerated federal railway statutes. Brightline's Boca Raton station, parking garage, and track infrastructure were built and improved with CRISI funds — a fact Brightline did not dispute.

Brightline had argued that § 22905(b) merely further defines who qualifies as a rail carrier under 49 U.S.C. § 10102(5) and does not independently extend RLA coverage to entities outside STB jurisdiction. The court rejected that reading, applying the canon against surplusage: if § 22905(b) did nothing more than restate the § 10102(5) definition, its specific cross-references to the RLA, the Railroad Retirement Act of 1974, and the Railroad Unemployment Insurance Act would be meaningless. The court also noted that the ruling aligns with the established congressional practice of conditioning receipt of federal funds on compliance with federal statutory requirements.

The NMB had certified the TWU as the employees' representative following a majority vote in January 2025, and the TWU had already notified Brightline of its intent to negotiate over pay and working conditions before the court issued its ruling. With summary judgment granted in the NMB's favor, the case is closed.

The ruling's practical reach is narrow — it turns on the specific combination of intrastate operations and CRISI grant funding — but it resolves a previously open question about whether the CRISI program's labor-law conditions can independently trigger RLA jurisdiction for railroads that would otherwise fall outside the federal regulatory framework.