Teamsters Local Union No 355 v. Ensinger Penn Fibre Inc
24-1037
3rd Cir.Apr 14, 2025Background
- Chad Hall, a Teamsters Union member, was terminated by Ensinger Penn Fibre, Inc. after leaving his workstation without permission for the third time in a month.
- The termination was governed by a collective bargaining agreement (CBA), which required "just cause" for termination.
- Hall and the Union grieved the termination, prompting arbitration.
- The arbitrator found Hall was terminated without just cause but declined to order reinstatement or backpay based on after-acquired evidence that Hall was under the influence of alcohol at work, a terminable offense under company policy.
- The Union sought to vacate the arbitrator’s refusal to grant remedies, arguing the decision exceeded the arbitrator's authority under the CBA.
- The District Court granted summary judgment to Ensinger, and the Union appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the arbitrator's reliance on after-acquired evidence to deny remedies exceeded his authority under the CBA | Arbitrator imposed his own "brand of industrial justice" unsupported by the record and acted beyond CBA limits | Arbitrator’s decision was supported by evidence and within contractually provided authority | Arbitrator’s remedy was rationally derived from CBA and employee handbook; decision affirmed |
| Whether written notice of the reason for termination under Article 12 precluded use of after-acquired evidence | CBA required written notice of grounds for discharge, so after-acquired evidence was irrelevant for denying reinstatement/backpay | Written notice relates only to initial discharge justification; after-acquired evidence pertains to remedy, not underlying just cause | Written notice requirement doesn't bar use of after-acquired evidence to limit remedies |
| Whether the arbitrator erred in finding Hall was under the influence at work | No record support for finding; issue not submitted to arbitrator | Evidence and testimony supported finding; authority over issues submitted for arbitration | Arbitrator’s factual finding on inebriety was supported and deferred to |
| Whether after-acquired evidence doctrine applied to deny both reinstatement and backpay | CBA didn't contemplate this, and the District Court erred in its application | Doctrine properly applied to remedy, with discovery timing crucial | After-acquired evidence doctrine applied; no reinstatement or backpay granted |
Key Cases Cited
- Major League Baseball Players Ass’n v. Garvey, 532 U.S. 504 (2001) (courts cannot review merits of arbitration awards or correct factual/legal errors if award draws essence from CBA)
- United Paperworkers Int’l Union v. Misco, 484 U.S. 29 (1987) (arbitrator's factual and interpretive errors do not provide basis to vacate award unless completely unsupported)
- McKennon v. Nashville Banner Publ’g Co., 513 U.S. 352 (1995) (after-acquired evidence doctrine limits remedies for unjust termination based on later-discovered employee misconduct)