NFL Players Ass'n v. NFL - 831 F.3d 985 (8th Cir. 2016)

Rule:

In an arbitration case, the role of the courts is very limited. Under the Labor Management Relations Act of 1947, Congress evinced a preference for private settlement of labor disputes without the intervention of government. A court thus does not apply its own view of what would be appropriate player discipline, and it does not review whether the arbitrator "correctly" construed the collective bargaining agreement. It is the arbitrator's construction which was bargained for; and so far as the arbitrator's decision concerns construction of the contract, the courts have no business overruling him because their interpretation of the contract is different from his. So long as the arbitrator is even arguably construing or applying the contract and acting within the scope of his authority, the arbitral decision must stand. Vacatur of an arbitration award is appropriate only when the decision does not draw its essence from the collective bargaining agreement, and the arbitrator instead has dispensed his own brand of industrial justice.

Facts:

During the 2014 football season, National Football League Commissioner Roger Goodell suspended Minnesota Vikings running back Adrian Peterson indefinitely for conduct detrimental to the game of professional football, and fined Peterson a sum equivalent to six games' pay. Peterson's suspension stemmed from his plea of nolo contendere in November 2014 to a charge of misdemeanor reckless assault on one of his children. Peterson appealed his discipline to an arbitrator, who affirmed the suspension and fine. Peterson petitioned the district court to vacate the arbitration decision. The court granted the petition, and the League appealed. 

Issue:

Under the circumstances, was it proper for the district court to vacate the arbitration decision? 

Answer:

No.

Conclusion:

The court held that the parties bargained to be bound by the decision of the arbitrator, and that the arbitrator acted within his authority. According to the court, when two parties submit an issue to arbitration, it conferred authority upon the arbitrator to decide that issue. So long as the arbitrator was construing or applying the contract and acting within the scope of his authority, the arbitral decision must stand. In this case, the court saw no basis for setting aside the arbitrator's decision under a federal court's limited scope of review.