Yes, and more than once--the most recent being the Pinnacle award using the "new" policy in 2011.

Going back in time it has only historically happened when DOH and/or longevity were part of ALPA policy at the time. (Go figure.)

Besides, the CAL merger committee proposal places pilots who were furloughed at merger announcement/closing, including some with less than a year on the property, above UAL widebody FOs who had never been furloughed. So I guess we can agree that both sides are fine with placing furloughed pilots above active pilots????