Textile Workers Union of America v. Lincoln Mills of Alabama

United States Court of Appeals for the Fifth Circuit · 1956 · Civil Procedure
230 F.2d 81 (1956)
Updated
civprofederal jurisdictionlabor arbitrationcollective bargaining agreementsspecific performanceLMRA § 301arbitrationcollective bargaining agreement

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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One of 10 multiple-choice questions for this case. Pick an answer to see why.
Great Plains Steelworks, a manufacturer in Tulsa, signed a collective bargaining agreement with Local 412. After the company refused to arbitrate a dispute over shift assignments, the union sued in federal district court seeking only an order compelling arbitration, and Oklahoma law provides no basis for specific enforcement of executory arbitration promises in such contracts.

How should the federal court rule on the employer's motion to dismiss?

Explanation. The majority drew a sharp distinction between jurisdiction and entitlement to relief. Section 301(a) gives federal courts jurisdiction over suits alleging violations of collective bargaining agreements, but it does not itself create a substantive right or remedy compelling specific performance of an executory arbitration promise. If no applicable federal or state law authorizes such enforcement, the complaint should be dismissed for failure to state a claim, even though jurisdiction exists. (Derived from Textile Workers Union of America v. Lincoln Mills of Alabama (1956).)