506 F. App'x 455
6th Cir.2012Background
- Pierre’s Ice Cream fired Arndt and Bonness after their FMLA leave expired following work-related injuries.
- Arndt’s return was postponed; Bonness needed six months; both requested additional leave and produced workers’ compensation claims.
- CBA permits discretionary unpaid leaves and sets procedures; other provisions reference FMLA and year-long absences.
- Arbitrator held that most F and G provisions don’t apply to work-related injuries and found lack of good cause for firing.
- Arbitrator concluded the company failed to investigate injuries and could not rely on certain leave rules without considering work-related context.
- District court denied vacatur; the Sixth Circuit reviews arbitration awards narrowly and affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did arbitrator exceed authority by interpreting the CBA? | Companies argue the arbitrator did not construe the CBA, thus exceeded authority. | Union contends the arbitrator properly interpreted the CBA to reach the decision. | No; arbitrator reasonably construed the CBA within authority. |
| Was the arbitrator’s interpretation sufficiently grounded in the CBA to survive deferential review? | Companies allege the interpretation was implausible and not tethered to the contract terms. | Union asserts the arbitrator’s interpretation was a good-faith contract construction. | Yes; the interpretation was a plausible, good-faith construction. |
| Does the arbitrator’s decision rest on a permissible balance of substantive and procedural just-cause analysis? | Companies claim misapplication of just-cause standards under Article V. | Union argues the arbitrator properly weighed procedural and substantive factors. | Yes; award grounded in legitimate interpretation of just-cause. |
Key Cases Cited
- Uhl v. Komatsu Forklift Co., 512 F.3d 294 (6th Cir. 2008) (narrow review of arbitration awards)
- Michigan Family Res., Inc. v. SEIU Local 517M, 475 F.3d 746 (6th Cir. 2007) (arbiter’s interpretation must be plausible; deference)
- Major League Baseball Players Ass’n v. Garvey, 532 U.S. 504 (2001) (limits on courts reviewing arbitration under federal policy)
- Titan Tire Corp. v. United Steelworkers of Am., Local 890L, 656 F.3d 368 (6th Cir. 2011) (deferential review; contract interpretation plausibility)
- Equitable Res., Inc. v. United Steel, Local 8-512, 621 F.3d 538 (6th Cir. 2010) (arbiter decision within contract interpretation bounds)
- Coolidge v. Riverdale Local Sch. Dist., 797 N.E.2d 61 (Ohio 2003) (context of just-cause and procedural due process)
- Bickers v. W. & S. Life Ins. Co., 879 N.E.2d 201 (Ohio 2007) (workers’ compensation context in contractual interpretation)