E. Associated Coal Corp. v. Mine Workers - 531 U.S. 57, 121 S. Ct. 462 (2000)

Rule:

In deciding whether a collective bargaining agreement contractual requirement, that is awarded by an arbitrator, falls within the legal exception that makes unenforceable a collective bargaining agreement that is contrary to public policy, any such public policy must be explicit, well defined, and dominant. It must be ascertained by reference to the laws and legal precedents and not from general considerations of supposed public interests.

Facts:

The arbitration provisions in a coal mining company's collective bargaining agreement with a mine worker's union specified that the company had to prove in binding arbitration that it had "just cause" to discharge an employee, or else the arbitrator would order the employee reinstated. A truck driver employee, covered by the collective bargaining agreement, was subject to Department of Transportation regulations promulgated under a provision of the Omnibus Transportation Employee Testing Act of 1991 requiring random drug testing of workers engaged in "safety-sensitive" tasks. On two occasions, the employee tested positive for marijuana, although he did not operate a vehicle under the influence of drugs. After each of these occasions, the company sought to discharge the employee. Each time, the union went to arbitration, and the arbitrator (1) concluded that the drug use did not amount to "just cause," and (2) ordered the employee's conditional reinstatement. The company filed suit in the district court to vacate the award. The district court ordered the enforcement of the award and concluded that the employee's conditional reinstatement did not violate the strong regulation based public policy against drug use by workers who perform safety sensitive functions. The appellate court affirmed. A writ of certiorari was granted. 

Issue:

Did considerations of public policy require courts to refuse to enforce an arbitration award ordering an employer to reinstate an employee truck driver who twice tested positive for marijuana? 

Answer:

No.

Conclusion:

The Court affirmed the lower courts’ decisions. The Court held that the arbitration award represented an agreement as to the proper meaning of the collective bargaining agreement's words as to "just cause" for reinstatement. Due to policies in favor of rehabilitation, there was no explicit, well defined, dominant public policy to which the arbitrator's decision ran contrary.