Textile Workers Union of America v. Lincoln Mills of Alabama
Facts
The employer and union entered into a written collective bargaining agreement effective June 27, 1953, with grievance procedures in Article VIII and arbitration provisions in Article IX(F) for unresolved disputes concerning wages, pay rates, hours, or other conditions of employment. The union filed ten grievances in June 1954, and the employer processed them through the contractual procedures but rejected them on various dates on and after July 14, 1954. The agreement terminated on July 3, 1954, pursuant to timely notice of termination. The union then demanded arbitration under Article IX(F), the employer refused, and the union brought this action to compel arbitration.
Issue
Does § 301(a) of the Labor Management Relations Act, alone or together with other applicable law, authorize a federal court to compel specific performance of an executory arbitration clause in a collective bargaining agreement? If not, does the complaint state a claim for relief when the union seeks an order requiring arbitration of the grievances?
Rule
Federal courts have jurisdiction under § 301(a) to adjudicate suits alleging violation of contracts between employers and labor organizations in industries affecting commerce, but § 301(a) does not itself furnish a substantive rule or remedy compelling arbitration. In the absence of some applicable federal or state source of law authorizing specific enforcement, an executory agreement to arbitrate grievances in a collective bargaining agreement will not be specifically enforced; and the United States Arbitration Act does not authorize such enforcement where the collective bargaining agreement is a contract of employment excluded by 9 U.S.C. § 1.
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