North Atlantic States Regional Council of Carpenters, Local Union No. 290 v. T20 World Cup USA, Inc., 2:24-cv-07172

The North Atlantic States Regional Council of Carpenters, Local Union No. 290 (Petitioner) and T20 World Cup USA, Inc. (Respondent) signed an agreement for the union to supply carpentry labor for a temporary cricket stadium project in New York.
The agreement referenced the Petitioner’s collective bargaining agreement (CBA) and required all work and payments to align with this CBA.
A dispute arose when Respondent allegedly barred union carpenters from work during the project dismantling phase, prompting the union to file a grievance and pursue arbitration under the CBA’s procedures.
A Joint Committee held an arbitration hearing (without Respondent’s participation) and awarded the union $127,270.79 for unpaid wages and benefits.
Petitioner then filed this federal action under §301 of the LMRA to confirm the arbitration award; Respondent moved to dismiss, challenging subject-matter jurisdiction and the applicability of the CBA’s arbitration provisions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Subject-matter jurisdiction under LMRA	The agreement is a qualifying labor contract incorporating the CBA	No jurisdiction since Respondent was not a direct CBA signatory	Jurisdiction exists; CBA incorporated by reference in contract
Incorporation of CBA and arbitration clause	CBA terms are expressly incorporated by reference in the agreement	Agreement does not incorporate or bind Respondent to the CBA	CBA—and its arbitration—incorporated; Respondent is bound
Validity/enforceability of arbitration award	Joint Committee’s award is final and binding per CBA and agreement	Joint Committee lacked jurisdiction; award should be vacated	Award confirmed; deferential standard for labor arbitration
Attorney’s fees and costs	Seeks fees/costs due to Respondent’s bad faith noncompliance	No express statutory authority for such fees	Fees and costs awarded for bad faith and to further arbitration

D.H. Blair & Co. v. Gottdiener, 462 F.3d 95 (2d Cir. 2006) (arbitration awards require judicial confirmation and are strongly deferred to)
Porzig v. Dresdner, Kleinwort, Benson, N. Am. LLC, 497 F.3d 133 (2d Cir. 2007) (courts grant great deference to labor arbitration awards)
Gen. Drivers, Warehousemen & Helpers, Local Union No. 89 v. Riss & Co., 372 U.S. 517 (1963) (arbitrator’s decision is binding if chosen method of dispute resolution)
Retail Clerks Int’l Ass’n v. Lion Dry Goods, 369 U.S. 17 (1962) (section 301 contracts under LMRA broadly construed to include labor agreements)