United Steelworkers v. American Manufacturing Co.

Background

A union filed a grievance on behalf of a worker who had left work after an injury and accepted a workers’ compensation settlement stating he was 25% permanently partially disabled. Two weeks after that settlement, the union said the worker should return to his job under the contract’s seniority rules. The employer refused to arbitrate, and lower courts stopped arbitration, calling the grievance baseless.

Reasoning

The Court reviewed the collective bargaining agreement, which promised arbitration of disputes about the meaning, interpretation, and application of the contract and contained a no-strike clause. Relying on the national labor policy that favors settling grievances by the parties’ chosen method, the Court said courts should not decide the merits of contract disputes that fall on their face within the agreement’s coverage. Instead, judges must check only whether the claim is one the contract covers and then send it to the arbitrator to interpret and apply the contract.

Real world impact

The decision reversed the lower courts and required arbitration of the union’s grievance. It means employers and unions must generally use arbitration to resolve contract disputes, even when a court thinks a claim is weak. The ruling enforces the parties’ agreement to let arbitrators interpret contract terms and reduces judges’ involvement in workplace grievance decisions.

Dissents or concurrances

A concurrence emphasized that the arbitration promise itself is a contract and that courts still decide the threshold question of whether the parties agreed to arbitrate the particular dispute, unless the contract clearly assigns that question to the arbitrator.