Teamsters Local Union No. 783 v. Anheuser-Busch, Inc., 626 F.3d 256

Local 783 and Anheuser-Busch were governed by a broad Collective Bargaining Agreement (CBA) that provides arbitration for grievances arising under or relating to interpretation of the CBA, subject to a mutual adjustment failure.
The Pension Plan for hourly employees is a separate document not covered by the CBA and contains its own dispute-resolution mechanism.
Section 24 of the CBA references the Pension Plan; Section 14.3 of the Pension Plan establishes an exclusive internal process for pension-claims disputes.
Jerry T. Vincent, a Local 783 official and former AB employee, pursued retirement benefits and claimed uninterrupted seniority under the CBA upon return to AB.
Vincent’s grievance was denied by the Pension Plan’s appeals process, AB alerted that pension issues were not arbitrable under the CBA, and Local 783 sought to compel arbitration in federal court.
The district court granted summary judgment for AB, and Local 783 appealed, challenging both timeliness and arbitrability.
The Sixth Circuit held the complaint was not time-barred and affirmed the district court’s ruling that the pension-claims portion of Vincent’s grievance was not arbitrable under the CBA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Local 783’s suit is time-barred under NLRA §10(b)	Local 783 argued timely filing; AB’s letters did not unequivocally refuse arbitration.	AB contended the six-month period began when it asserted nonarbitrability and sought clarification.	Not time-barred; AB did not unequivocally refuse to arbitrate.
Whether Vincent’s pension grievance is arbitrable under the CBA	Grievance rooted in CBA Section 11 and its relation to pension rights, within arbitration scope.	Pension rights/benefits are governed by the Pension Plan and its exclusive dispute resolution, not the CBA arbitration.	Not arbitrable; Pension Plan provisions expressly exclude pension claims from CBA arbitration.

Int'l Union v. Cummins, Inc., 434 F.3d 478 (6th Cir. 2006) (presumption of arbitrability; broad clauses; exclusion required for non-arbitrable disputes)
Cooper Tire & Rubber Co., 474 F.3d 271 (6th Cir. 2007) (arbitrability decision guided by four principles; avoid merits; broad arbitration favored)
Commonwealth Aluminum Corp., 162 F.3d 447 (6th Cir. 1998) (insurance/benefits plan with alternative dispute resolution excludes arbitration)
ISP Chems., Inc., 261 Fed.Appx. 841 (6th Cir. 2008) (incorporation by reference into CBA; clear reference to Pension Plan and exclusion)
McCreedy v. Local Union No. 971, UAW, 809 F.2d 1232 (6th Cir. 1987) (six-month NLRA limitations for union-arbitration suits)