Law School Case Brief
United Steelworkers of Am. v. Am. Mfg. Co. - 363 U.S. 564, 80 S. Ct. 1343 (1960)
Where the parties agree to submit all grievances to arbitration, the courts have no business weighing the merits of a grievance, considering whether there is equity in a particular claim, or determining whether there is particular language in the written instrument which will support the claim.
The collective bargaining agreement (CBA) between the United Steelworkers of America (Union) and an employer, the American Manufacturing Co. (AMC), contained a provision that called for all grievances not adjusted to be submitted to arbitration. AMC refused to submit a grievance to arbitration because it found the grievance to be frivolous and not subject to arbitration under the CBA. The Union brought an action to compel arbitration. The district court granted AMC's motion for summary judgment, and the appellate court affirmed on the basis that the grievance was frivolous. The Union filed for a writ of certiorari.
Can an employer be compelled to submit the grievance to arbitration?
Upon the Union's writ of certiorari, the appellate court's decision was reversed. The Union's grievance claimed that AMC had violated a specific provision of the CBA. AMC contended that it had not violated the CBA. Thus, a dispute existed between the parties as to the meaning, interpretation, and application of the CBA. The CBA required arbitration of all unresolved claims, not just those that a court deemed meritorious; thus, the district court erred in granting AMC's motion for summary judgment. The courts had no business weighing the merits of the grievance or determining whether the language of the CBA supported the claim.
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