AmeriPride Services, LLC v. Teamsters Local 87
1:21-cv-00969
E.D. Cal.Sep 6, 2024Background
- AmeriPride Services, LLC and Aramark Uniform & Career Apparel, LLC (collectively "Aramark") operate uniform and linen service facilities in California.
- Teamsters Locals 87 and 386 represent employees at Bakersfield and Merced facilities that were formerly owned by AmeriPride and later acquired by Aramark.
- Separate collective bargaining agreements (CBAs) covered those two facilities, in addition to a broader "Master" CBA between Aramark and the Teamsters covering multiple locations.
- Teamsters filed grievances seeking to have former AmeriPride locations (now Aramark) covered by the Master CBA under its after-acquired clause, arguing those locations are "new or additional depots".
- Aramark refused to arbitrate the grievances under the Master, prompting cross-motions: Aramark seeking a declaratory judgment of non-arbitrability, Teamsters seeking to compel arbitration under the Master.
- The parties stipulated to summary judgment, with no factual disputes but significant disagreement over the legal effect of the overlapping CBAs and the scope of arbitrability.
Issues
| Issue | Plaintiff's Argument (Aramark) | Defendant's Argument (Teamsters) | Held |
|---|---|---|---|
| Duty to Arbitrate under Master CBA | Separate AmeriPride CBAs exclude the claims from Master coverage | Grievances require interpretation of Master; arbitration presumed | Must arbitrate; Master clause applies |
| Whether the Merits or Arbitrability is at Issue | Court must decide if duty exists due to AmeriPride CBAs | Only arbitrability is before court; merits for arbitration | Arbitrability only; merits for arbitrator |
| Impact of NLRA—“Unlawful objective” defense | Arbitration would unlawfully merge units, violating NLRA | Arbitrator can render lawful interpretation; only if all possible readings unlawful is arbitration barred | No bar: not all readings unlawful |
| Procedural Issue: Consolidated Arbitration | Court should decide whether to consolidate arbitrations | Consolidation is a procedural question for the arbitrator | For arbitrator to decide |
| Estoppel & Waiver | Teamsters accepted benefits under AmeriPride CBAs, so are estopped/waived | No estoppel/waiver; Teamsters seek arbitration as soon as rejected | No estoppel/waiver shown |
| Attorney’s Fees | No bad faith; refusal to arbitrate was justified | Aramark refused arbitration in bad faith; fees warranted | No fees: refusal not frivolous |
Key Cases Cited
- United Steelworkers of Am. v. Warrior & Gulf Nav. Co., 363 U.S. 574 (1960) (presumption in favor of arbitrability in labor disputes; scope of arbitration is a question for courts unless explicitly delegated)
- AT&T Techs., Inc. v. Commc’ns Workers of Am., 475 U.S. 643 (1986) (unless parties clearly provide otherwise, courts decide arbitrability)
- Granite Rock Co. v. Int’l Bhd. of Teamsters, 561 U.S. 287 (2010) (arbitrability of labor disputes determined by courts unless unmistakably delegated)
- United Food & Commercial Workers Union v. Alpha Beta Co., 736 F.2d 1371 (9th Cir. 1984) (arbitration is only barred if all interpretations of the contract would violate federal law)
- John Wiley & Sons, Inc. v. Livingston, 376 U.S. 543 (1964) (procedural issues related to arbitration are for the arbitrator, not courts)
- Martin v. Yasuda, 829 F.3d 1118 (9th Cir. 2016) (waiver of right to compel arbitration is a question for the court)