Washington Metropolitan Area Transit Authority v. Local 689, Amalgamated Transit Union, 804 F. Supp. 2d 457

WMATA and Local 689 submitted a dispute to a three-person Board under the WMATA Compact and the Standards Act, 40 U.S.C. §§ 18301-18304, seeking terms for a new CBA covering 2008–2012.
The Board issued an Award in November 2009 granting wage increases and pension decisions; a partial dissent argued the Award violated the Standards Act’s factors and written-critique requirements.
The Court first concluded the Board’s award largely complied with the Act but remanded for a Second Supplemental Opinion detailing compliance with 40 U.S.C. § 18303(d).
The Board issued a Second Supplemental Opinion in March 2011 addressing the seven statutory factors; WMATA challenged the Opinion as incomplete and not adequately tied to record evidence.
The Court, after briefing and a teleconference on private communications between Kasher and Roth, held that the Second Supplemental Opinion largely satisfied the Standards Act’s requirements and confirmed the unconfirmed wage and pension provisions.
The Court denied WMATA’s motion to vacate or disqualify Board members and granted the Union’s motion to confirm the arbitration award to the extent not previously confirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the Second Supplemental Opinion satisfy the Standards Act requirements?	WMATA contends the Opinion fails to connect facts to conclusions and lacks detailed factor-by-factor analysis.	Union maintains the Opinion discusses each factor with record support and is sufficiently reasoned.	Yes; the Opinion complies with the Act and supports the Award.
Was the Board's consideration of the public welfare supported by substantial evidence?	WMATA argues the public-welfare conclusions are unsupported and the funding sources speculative.	Union asserts evidence shows the Board’s funding and impact analyses were reasonable and tied to record evidence.	Yes; conclusions regarding public welfare are supported by substantial evidence.
Did ex parte/private communications between Kasher and Roth prejudice WMATA requiring vacatur?	WMATA argues such communications tainted the decision and due process was violated.	Union argues communications were akin to typical panel deliberations and did not prejudice WMATA.	No; private communications did not prejudice WMATA and do not require vacatur.
Did the Court apply an improper standard of review by overhauling the Board’s reasoning?	WMATA urges de novo review of the Board’s reasoning and evidence.	Union contends the Court used a hybrid standard, preserving deference while ensuring statutory compliance.	No; the Court applied the hybrid standard and affirmed the Board’s reasoning.

MCI Constructors, LLC v. City of Greensboro, 610 F.3d 849 (4th Cir. 2010) (arbitration review is narrow but standards Act imposes specific criteria)
Mastro v. Apfel, 270 F.3d 171 (4th Cir. 2001) (court may not substitute its own view; must find substantial evidence)
Ohio Valley Environmental Coalition v. Aracoma Coal Co., 556 F.3d 177 (4th Cir. 2009) (vacatur for failure to articulate adequate explanation)
State Farm Mut. Auto. Ins. Co. v. State Farm, 463 U.S. 29 (1983) (judicial review standards require articulation of reasoning and evidentiary support)
Getty v. Fed. Sav. & Loan Ins. Corp., 805 F.2d 1050 (D.C. Cir. 1986) (written decisions must connect facts to conclusions with detail)
Dickson v. Sec'y of Defense, 68 F.3d 1396 (D.C. Cir. 1995) (requirement for connection between record evidence and conclusions)
Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (evidence sufficiency standard for substantial support)