Law School Case Brief
United Steelworkers of Am. v. Enter. Wheel & Car Corp. - 363 U.S. 593, 80 S. Ct. 1358 (1960)
The question of interpretation of a collective bargaining agreement is a question for the arbitrator. 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.
Employees of respondent Enterprise Wheel & Car Corp. (Enterprise) were discharged during the term of a collective bargaining agreement (CBA) containing a provision for arbitration of disputes, including differences "as to the meaning and application" of the CBA, and a provision for reinstatement with back pay of employees discharged in violation of the CBA. The discharges were arbitrated after the CBA had expired, and the arbitrator found that they were in violation of the CBA and that the CBA required reinstatement with back pay, minus pay for a 10-day suspension and such sums as the employees had received from other employment. Enterprise refused to comply with the award, and the District Court directed it to do so. The Court of Appeals for the Fourth Circuit held that failure of the award to specify the amounts to be deducted from the back pay rendered the award unenforceable, though that defect could be remedied by requiring the parties to complete the arbitration. Furthermore, the appellate court held that an award for back pay subsequent to the date of expiration of the CBA could not be enforced, and the requirement for reinstatement of the discharged employees was unenforceable because the CBA had expired. Petitioners United Steelworkers of Amercia (USWA) and the employees sought a writ of certiorari.
Could the federal courts overrule the arbitrator’s construction and interpretation of a collective bargaining agreement (CBA)?
The United States Supreme Court held that federal courts should decline to review the merits of arbitration awards under collective bargaining agreements (CBAs). According to the Court, the question of interpretation of the CBA is a question for the arbitrator, and the courts have no business overruling his construction of the contract merely because their interpretation of it is different from his. The opinion of the arbitrator, as it bore upon the award of back pay beyond the date of the CBA's expiration and reinstatement, was ambiguous; but mere ambiguity in the opinion accompanying an award was not a reason for refusing to enforce the award, even when it permitted the inference that the arbitrator may have exceeded his authority. As such, the Court held that the Fourth Circuit, in ruling that the award was barred by the termination of the CBA, exceeded its proper function under the arbitration clause, which was to determine whether a grievance was arbitrable, and not the merits of an arbitrable grievance.
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