Monday, May 19, 2014

United Steelworkers of America v. American Manufacturing Co. case brief summary


PROCEDURAL POSTURE: Petitioner union sought review of an order of the United States Court of Appeals for the Sixth Circuit, which affirmed the district court's decision to grant respondent employer's motion for summary judgment in the action that the union brought to compel arbitration of a grievance pursuant to the parties' collective bargaining agreement.
OVERVIEW: The collective bargaining agreement (CBA) between the union and the employer contained a provision that called for all grievances not adjusted to be submitted to arbitration. The employer 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 the employer's motion for summary judgment, and the appellate court affirmed on the basis that the grievance was frivolous. Upon the union's writ of certiorari, the appellate court's decision was reversed. The union's grievance claimed that the employer had violated a specific provision of the CBA. The employer 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 the employer'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.

OUTCOME: The Court reversed the lower court's decision because it found that arbitration should have been ordered.

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