4th Cir.

Exclusive Jets, LLC d/b/a Fly Exclusive v. United States Department of Labor, Administrative Review Board and Michael J. Jones

April 30, 2026 ·25-1190 ·Panel Decision ·Judge Wynn · By Maria Santos

The Fourth Circuit affirmed the Administrative Review Board's finding that a pilot was wrongfully terminated for reporting aviation safety concerns. However, the court vacated the damages portion of the decision because the Board applied an incorrect legal standard regarding the employee's duty to mitigate damages.

Background

Exclusive Jets, LLC fired Michael Jones, a pilot, after he reported various aircraft safety issues and mechanical irregularities. An administrative law judge found the termination violated the Aviation Reform Act, and the Administrative Review Board affirmed the liability determination. The Board, however, applied a heightened standard for mitigating damages, requiring proof of gross or egregious misconduct by the employee.

The court’s reasoning

The court held that the pilot’s actions constituted protected activity under the Aviation Reform Act and that the employer failed to meet its burden of proving it would have taken the same action absent the protected conduct. The court found the Administrative Review Board erred by requiring a showing of gross or egregious misconduct to toll back-pay liability. The correct standard requires the employer to prove the employee failed to exercise reasonable diligence in seeking suitable employment.

Thus, we grant in part and deny in part the petition for review and remand to the ARB with instructions to apply the correct legal standard to assess Jones’s duty to mitigate damages.

49 U.S.C. § 42121

What it means going forward

The decision clarifies that the duty to mitigate damages in Aviation Reform Act cases is based on reasonable diligence, not gross misconduct, and remands the damages calculation to the agency for re-evaluation under the correct standard.