The union and employer entered into a collective bargaining agreement in 1953 that provided for no strikes or work stoppages and for a grievance procedure whose final step, available to either party, was arbitration. Several grievances involving workloads and work assignments were processed through the grievance procedure and denied by the employer. The union demanded arbitration, but the employer refused. The union then brought suit in federal district court to compel arbitration.
Issue
Does § 301(a) of the Labor Management Relations Act do more than confer jurisdiction, so that a federal court may specifically enforce a collective bargaining agreement's promise to arbitrate grievance disputes? If so, is such relief barred by the Norris-LaGuardia Act?
Rule
Section 301(a) is more than jurisdictional: it authorizes federal courts to fashion and apply federal law, drawn from the policy of the national labor laws, to enforce collective bargaining agreements. That federal law includes specific enforcement of agreements to arbitrate grievance disputes, and state law may be used only if compatible with § 301's purposes and then only as absorbed federal law.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
Prairie Alloy Works in Gary, Indiana and Local 88 of the Midlake Metal Workers signed a collective bargaining agreement containing a no-strike clause and a grievance procedure whose final step is arbitration at the request of either party. After Prairie Alloy denied several grievances over shift assignments, the union demanded arbitration, and the company refused.
If the union files a § 301 action in federal district court seeking an order compelling arbitration, what is the best result?
Explanation. The majority held that § 301 is more than jurisdictional. It authorizes federal courts to fashion federal law for enforcement of collective bargaining agreements, and that federal law includes specific enforcement of promises to arbitrate grievance disputes. The presence of a no-strike clause reinforces the federal policy favoring enforcement because grievance arbitration is treated as the quid pro quo for labor peace.