Jim Walter Resources, Inc. v. United Mine Workers of America, Internationial Union, 663 F.3d 1322

Jim Walter and the UMWA entered into a 2007–2011 labor agreement covering Jim Walter’s coal mining operations.
Memorial periods up to 10 days per an MOU could be designated at any mine with reasonable notice; memorial periods must be for legitimate reasons.
On Oct. 14 and Oct. 28, 2008, four Local Unions observed memorial periods at Jim Walter mines; Jim Walter contends these were not legitimate.
Jim Walter sued the Union for damages arising from the memorial-period stoppages, arguing the no-strike regime violated the contract.
The district court granted summary judgment in favor of arbitration, interpreting the contract’s dispute-resolution machinery as covering the employer’s claim.
The court reversed in part and remanded, holding the employer’s claim was not within the employee-oriented grievance/arbitration machinery.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are damages claims arising from alleged no-strike violations arbitrable?	Jim Walter argues XXVII’s ‘all disputes and claims’ is limited to disputes within the arbitration machinery; employer-initiated claims are not covered.	Union argues the contract’s sweeping ‘all disputes and claims’ language and the arbitration framework cover the employer’s damages claim.	No; damages claims are not arbitrable under the employee-only grievance machinery.
Does Article XXVII create a general presumption of arbitrability for employer-initiated disputes?	Jim Walter contends the no-strike and arbitration clauses do not automatically cover employer claims absent explicit inclusion.	Union relies on a broad-arbitrability reading consistent with the contract’s aspirational language to resolve disputes through the contract, not courts.	The district court’s arbitrability finding is reversed; employer claims are not within the employee-only grievance framework.
How should the court interpret the interaction between XXVII and Article XXIII regarding arbitration eligibility?	The contract limits arbitral reach to disputes that can be processed by XXIII’s employee-oriented procedures.	The arbitration clause should be read to cover disputes broadly wherever the contract contemplates arbitration.	Employee-oriented procedures limit arbitration; the employer’s damages claim falls outside the arbitration machinery.

United Steelworkers v. American Mfg. Co., 363 U.S. 564 (1960) (arbitration is a matter of contract; courts decide whether arbitrable)
United Steelworkers v. Warrior & Gulf Navigation Co., 363 U.S. 574 (1960) (question of arbitrability for contract disputes is judicially decided)
United Steelworkers v. Enterprise Wheel & Car Corp., 363 U.S. 593 (1960) (arb. presumption and contract coverage principles)
Drake Bakeries, Inc. v. Local 50, 370 U.S. 254 (1962) (employer damages arbitrable when contract contemplates employer grievances)
Atkinson v. Sinclair Refining Co., 370 U.S. 238 (1962) (employee-oriented grievance procedure; no automatic arbitration of employer claims)
Firestone Tire & Rubber Co. v. IUR, Cork, L&LP Workers, 476 F.2d 603 (5th Cir. 1973) (employee-oriented machinery limits arbitration of employer claims)
Friedrich v. Local Union No. 780, 515 F.2d 225 (5th Cir. 1975) (same reasoning; limits arbitration to employee-centered procedures)
ITT World Communications, Inc. v. Communications Workers of America, 422 F.2d 77 (2d Cir. 1970) (presumption of arbitrability; but exclude where exclusion language is clear)
Granite Rock Co. v. Teamsters, 130 S. Ct. 2847 (2010) (reaffirmed need to construe arbitration clauses to cover disputes unless clearly excluded)