International Union v. Trane U.S. Inc., 946 F.3d 1031

Trane announced closure of its Fort Smith, AR manufacturing plant in Feb. 2017; parties executed a Memorandum of Agreement extending the 2013–2017 CBA until the earlier of the plant closing or April 1, 2019.
The Union filed two grievances after the closing: (1) denial of a "bridge" benefit (one year protected service to avoid pension reduction), and (2) denial of a temporary early-retirement pension supplement described in a Plan SPD.
Trane denied both grievances, refused arbitration, and the Union sued under § 301 to compel arbitration; the district court denied the motion to compel arbitration.
On appeal, the Eighth Circuit reviewed arbitrability de novo and parsed whether disputes fell within the CBA arbitration clause or were excluded as pension/plan matters.
Court held the bridge-benefit grievance arbitrable (reversing the district court) because it arises from a specific CBA provision (Article XX) and the Memorandum reconfirmed that provision.
Court held the temporary pension-supplement grievance not arbitrable (affirming the district court) because the dispute is rooted in Plan/SPD terms and the PIA expressly excluded plan-administration/claim disputes from arbitration; ERISA procedures govern.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Arbitrability of bridge benefit grievance	Bridge benefit is a bargained CBA term (Art. XX) and arbitrable	Claim implicates pension plan/plan administration and is excluded by Art. XIV §2(b)	Bridge grievance is arbitrable under Art. XIV §1; reversed and sent to arbitrator
Arbitrability of temporary pension supplement grievance	SPD language incorporated by reference makes dispute arbitrable	PIA/Art. XXVI incorporate plan but PIA ¶5 excludes plan-admin/SPD disputes from arbitration; ERISA governs	Not arbitrable; PIA ¶5 exclusion controls and ERISA remedies apply; affirmed

AT&T Tech., Inc. v. Communications Workers of Am., 475 U.S. 643 (U.S. 1986) (arbitration is contractual; courts decide arbitrability absent clear agreement otherwise)
Granite Rock Co. v. Int’l Bhd. of Teamsters, 561 U.S. 287 (U.S. 2010) (presumption of arbitrability applies only where parties intended arbitration)
Teamsters Local Union No. 688 v. Indus. Wire Prods., Inc., 186 F.3d 878 (8th Cir. 1999) (summary of arbitrability principles applied in this circuit)
United Steelworkers v. Warrior & Gulf Navigation Co., 363 U.S. 574 (U.S. 1960) (grievances excluded from arbitration only by clear contractual language or strong evidence of intent)
UAW v. Gen. Elec. Co., 714 F.2d 830 (8th Cir. 1983) (ambiguous exclusion requires most forceful evidence to bar arbitration)
3M Co. v. Amtex Sec., Inc., 542 F.3d 1193 (8th Cir. 2008) (courts look past labels to determine whether claims fall within arbitration clauses)
United Steelworkers v. Duluth Clinic, 413 F.3d 786 (8th Cir. 2005) (side agreements affect whether disputes are subject to CBA arbitration)
Bakery Workers Local Union No. 362-T v. Brown & Williamson Tobacco Corp., 971 F.2d 652 (11th Cir. 1992) (agreements to accept plan benefits during CBA term can make related disputes arbitrable)