United Steelworkers of America v. Enterprise Wheel & Car Corp.

United States District Court · Labor Law

Labor LawSection 301ArbitrationCollective Bargaining AgreementsLMRA § 301Taft-Hartley Actgrievance arbitrationspecific performance

Facts

A collective bargaining agreement between the union and employer was in effect from April 5, 1956, to midnight April 4, 1957, and contained a Step Four grievance-arbitration provision stating that the umpire's decision would be final and binding on the parties. Eleven employees were discharged on January 18, 1957, and after the employer resisted arbitration, the court ordered it to submit the grievance to arbitration. The arbitrator later ordered reinstatement of the employees to their January 18, 1957 positions and awarded back pay, minus a ten-day suspension period and interim earnings. The employer refused to comply, arguing lack of jurisdiction, lack of finality, and that the arbitrator exceeded his authority by awarding reinstatement and back pay beyond the contract's expiration date.

Issue

After a district court compels arbitration under § 301 of the LMRA, may it in the same action require the employer to comply with the arbitrator's award notwithstanding the employer's claim that the award affects personal rights of individual employees? Also, did the arbitrator exceed his authority by awarding reinstatement and back pay beyond the expiration of the collective bargaining agreement?

Rule

When a district court orders specific performance of a collective bargaining agreement's arbitration clause under § 301, that order includes the contractually required final and binding effect of the arbitrator's decision, and the court retains jurisdiction to compel compliance with the award. An arbitrator does not exceed his authority by awarding reinstatement and continuing back pay beyond the contract's expiration where the employees did not accept the discharge as final and the remedy is necessary to make them whole for losses caused by the employer's wrongful discharge.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Cleveland, a union sued Ridgeway Fabrication, Inc. under § 301 to compel arbitration of a discharge grievance under a collective bargaining agreement stating that the arbitrator's decision would be final and binding. The district court ordered arbitration, the arbitrator later directed reinstatement and back pay, and Ridgeway refused to comply, arguing the court's authority ended once the hearing occurred.

How should the court rule on the union's motion in the same action to require compliance with the award?

Explanation. The majority held that when a district court orders specific performance of a collective bargaining agreement's arbitration clause, the order inherently includes the contract term making the arbitrator's decision final and binding. Otherwise the order would require a futile act. The court therefore retains jurisdiction in the same § 301 action to require compliance with the award.