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Textile Workers Union of America v. Lincoln Mills of Alabama

United States Court of Appeals for the Fifth Circuit · 1956 · Civil Procedure

Civil ProcedureFederal JurisdictionLabor ArbitrationCollective Bargaining AgreementsLMRA Section 301federal jurisdictionspecific performancearbitration

Facts

The union and employer entered a written collective bargaining agreement effective June 27, 1953, with grievance procedures in Article VIII and an arbitration provision in Article IX(F) for disputes arising from the operation or interpretation of the agreement concerning wages, pay, hours, or other conditions of employment. The union filed ten grievances in June 1954, and the employer processed them through the contract procedures up to rejection. The agreement terminated on July 3, 1954, pursuant to timely notice of termination. After the employer refused the union's request to arbitrate the grievances under Article IX(F), the union filed this action to compel arbitration.

Issue

Does Section 301(a) of the Labor Management Relations Act permit or require a federal court to specifically enforce an executory covenant to arbitrate grievances in a collective bargaining agreement? Relatedly, does the United States Arbitration Act authorize such enforcement here?

Rule

Section 301(a) gives federal courts jurisdiction over suits alleging violations of collective bargaining agreements, but it does not by itself create a substantive right or remedy to compel arbitration. In the absence of some applicable federal or state rule authorizing such relief, federal courts will not specifically enforce an executory agreement to arbitrate, and the United States Arbitration Act does not apply because a collective bargaining agreement is a 'contract of employment' excluded by Section 1 of that Act.

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Riverbend Glass Works, a manufacturer in Toledo, Ohio, signed a collective bargaining agreement with Midlake Industrial Employees Union. After Riverbend allegedly violated a grievance-processing clause, the union sued in federal district court seeking relief under Section 301(a), and Riverbend moved to dismiss solely because both sides are citizens of Ohio and the amount in controversy is modest.

How should the federal court rule on the jurisdictional objection?

Explanation. The majority treated Section 301(a) as a jurisdictional grant. A suit alleging violation of a contract between an employer and a labor organization in an industry affecting commerce may be brought in federal district court without regard to citizenship or amount in controversy. Whether the plaintiff can obtain the requested remedy is a separate merits question.