Kan. City Royals Baseball Corp. v. Major League Baseball Players Asso. - 532 F.2d 615 (8th Cir. 1976)

Rule:

A party may be compelled to arbitrate a grievance only if it has agreed to do so. The question of arbitrability is thus one of contract construction and is for the courts to decide. In resolving questions of arbitrability, the courts are guided by Congress's declaration of policy that arbitration is the desirable method for settling labor disputes. Accordingly, a grievance arising under a collective bargaining agreement providing for arbitration must be deemed arbitrable unless it may be said with positive assurance that the arbitration clause is not susceptible of an interpretation that covers the asserted dispute. Doubts should be resolved in favor of coverage. Consistent with these principles, a broad arbitration provision may be deemed to exclude a particular grievance in only two instances: (1) where the collective bargaining agreement contains an express provision clearly excluding the grievance involved from arbitration; or (2) where the agreement contains an ambiguous exclusionary provision and the record evinces the most forceful evidence of a purpose to exclude the grievance from arbitration.

Facts:

A dispute arose between the Club Owners and the Major League Baseball Players Association concerning the contractual status of two baseball players under the rules of major league baseball and a collective bargaining agreement. An arbitration panel made an award that relived the players of any contractual obligation to their baseball clubs, directed the removal of the players from reserved and disqualified lists, and ordered the major leagues to inform and instruct the baseball clubs that the reserve list rule and the no-tampering rule did not inhibit, prohibit or prevent clubs from negotiation with the players. The district court found that the players' grievances were within the scope of the arbitration panel's jurisdiction and that neither the arbitrator's resolution of the merits not the relief awarded exceeded the bounds of the panel's authority. The Club Owners appealed, arguing that the players’ grievances were not within the purview of the arbitration panel’s jurisdiction. They additionally argued that the arbitration panel's award exceeded the scope of its authority.

Issue:

Did the district court err in finding that the players’ grievances fall within the scope of the arbitration panel’s jurisdiction? 

Answer:

No.

Conclusion:

The Court noted that a party may be compelled to arbitrate a grievance only if it had agreed to do so, and in resolving the questions of arbitrability, the courts must be guided by Congress’ declaration of policy that arbitration was the desirable method for settling labor disputes. Accordingly, a grievance arising under a collective bargaining agreement providing for arbitration must be deemed arbitrable "unless it may be said with positive assurance that the arbitration clause was not susceptible of an interpretation that covered the asserted dispute. In the case at bar, the Court found that the collective bargaining agreement between the parties clearly permitted the arbitration of grievances relating to the reserved system. It, therefore, cannot be said that the Club Owners never consented to the arbitration of such grievances. Accordingly, the Court held that the arbitration panel had jurisdiction to hear and decide the grievances; the panel's award drew its essence from the collective bargaining agreement; and the relief fashioned by the district court was appropriate.