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Major League Baseball Players Ass'n v. Garvey - 532 U.S. 504

Rule:

Regarding the courts' limited role in reviewing the merits of arbitration awards, courts have no business weighing the merits of the grievance or considering whether there is equity in a particular claim. When the judiciary does so, it usurps a function which is entrusted to the arbitration tribunal. Consistent with this limited role, even in the very rare instances when an arbitrator's procedural aberrations rise to the level of affirmative misconduct, as a rule the court must not foreclose further proceedings by settling the merits according to its own judgment of the appropriate result. That step would improperly substitute a judicial determination for the arbitrator's decision that the parties bargained for in their agreement. Instead, the court should simply vacate the award, thus leaving open the possibility of further proceedings if they are permitted under the terms of the agreement.

Facts:

In the late 1980's, petitioner Major League Baseball Players Association (Association) filed grievances against the Major League Baseball Clubs (Clubs), claiming the Clubs had colluded in the market for free-agent services after the 1985, 1986 and 1987 baseball seasons, in violation of the industry's collective-bargaining agreement.  In a series of decisions, arbitrators found collusion by the Clubs and damage to the players. The Association and Clubs subsequently entered into a Global Settlement Agreement (Agreement), pursuant to which the Clubs established a fund to be distributed to injured players. Respondent Steve Garvey, a retired, highly regarded first baseman, submitted a claim for damages of approximately $3 million, alleging that his contract with the San Diego Padres was not extended to the 1988 and 1989 seasons due to collusion, however, but the arbitrator rejected his claim. The district court denied the motion but the appellate court reversed and directed the arbitration panel to enter an award in favor of Garvey. Petitioner Association sought review.

Issue:

Does the court usurp the authority of the arbitrator when it directs the arbitration panel to enter an award in favor of the respondent?

Answer:

Yes.

Conclusion:

The Supreme Court reversed the ruling of the appellate court, holding that the court usurped the arbitrator's role by resolving the dispute and barring further proceedings, a result at odds with governing law. The court has limited role in reviewing the merits of arbitration awards and courts have no business weighing the merits of the grievance or considering whether there is equity in a particular claim.

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