Washington Metropolitan Area Transit Authority v. Local 689, Amalgamated Transit Union, 818 F. Supp. 2d 888

WMATA is a regional transit authority formed by an interstate compact among DC, Maryland, and Virginia, operating mass transit in the DC area.
The 2008-2012 CBA terms were to be decided by a three-member Board under the Compact’s interest-arbitration framework.
The Board granted wage increases and pension provisions, but a member (Clark) argued the Award failed to comply with the Standards Act, 40 U.S.C. §§ 18301-18304.
WMATA appealed and Union sued to confirm the Award; the Court previously confirmed the Award except for wage and pension provisions and remanded for compliance with the Standards Act.
The Board issued a June 2010 Supplemental Opinion, which again lacked detailed analysis of the Standards Act factors, prompting renewed proceedings.
The Court held the Standards Act governs judicial review of WMATA arbitration, requiring a hybrid APA-like standard and a detailed, factor-specific written decision; it remanded for a Second Supplemental Opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
What standard of review applies?	WMATA argues APA-like substantial-evidence/arbitrary-or-capricious review.	Union argues against applying APA standards, preferring traditional arbitration review.	Court adopts a hybrid standard, applying APA-style review with written-factor analysis.
Does the Standards Act abrogate common-law arbitration for WMATA?	WMATA contends Act imposes stricter judicial review than common law.	Union contends Act does not override arbitration law or create novel review.	Court holds the Act abrogates pure common-law review and imposes APA-style scrutiny.
What is required in the Board’s written decision under the Act?	Written findings are sufficient if they reference factors.	Board failed to demonstrate analysis meeting statutory factors with substantial evidence.	Board must provide a detailed, factor-by-factor written analysis connecting facts to conclusions.
What remedy should the court impose for noncompliance?	We should confirm the Award and adjust only the disputed terms.	We should vacate or remand for proper compliance with the Standards Act.	Case remanded for a Second Supplemental Opinion; otherwise, summary-judgment motions denied without prejudice.

MCI Constructors, LLC v. City of Greensboro, 610 F.3d 849 (4th Cir. 2010) (arb. review standards; deference and grounds to vacate)
Paperworkers v. Misco, Inc., 484 U.S. 29 (Supreme Court, 1987) (limitations on arbitrator review; essence from contract)
Enterprise Wheel & Car Corp., 363 U.S. 593 (Supreme Court, 1960) (arbitrator not required to give reasons; scope of review)
Upshur Coals Corp. v. United Mine Workers, Dist. 31, 933 F.2d 225 (4th Cir. 1991) (manifest disregard and essence-from-contract concept)
Getty v. Fed. Sav. & Loan Ins. Corp., 805 F.2d 1050 (D.C. Cir. 1986) (requires actual consideration and explanation of factors, not boilerplate)
Tex Tin Corp. v. EPA, 935 F.2d 1321 (D.C. Cir. 1991) (remand when agency fails to explain path to decision)
Sterling Smokeless Coal Co. v. Akers, 131 F.3d 438 (4th Cir. 1997) (duty to consider all relevant evidence and provide rational connection)
Ohio Valley Environmental Coalition v. Aracoma Coal Co., 556 F.3d 177 (4th Cir. 2009) (requirement to consider relevant data and explain decisions)
Dickson v. Sec’y of Defense, 68 F.3d 1396 (D.C. Cir. 1995) (need for explicit reasoning linking facts to conclusions)
Clinchfield Coal Co. v. Dist. 28, United Mine Workers, 720 F.2d 1365 (4th Cir. 1983) (arbitrator cannot shield award with lack of discussion)