Supreme Court of the United States
United Paperworkers International Union, Afl-Cio v. Misco, Inc.
December 1, 1987484 U.S. 29
Summary
The Court, in an opinion by Justice White, reversed the judgment refusing to enforce an arbitration award reinstating a discharged employee. Courts may not substitute their factual findings, contract interpretations, or remedial judgments for those of an arbitrator acting within the authority conferred by a collective-bargaining agreement. The arbitrator's exclusion of after-discovered evidence did not justify setting aside the award. The asserted public policy lacked the required grounding in laws and legal precedents, and its violation had not been clearly established. The Court left unresolved whether the public-policy exception applies only when an award violates positive law or requires unlawful conduct. Justice Blackmun, joined by Justice Brennan, concurred, emphasizing the decision's narrow grounds and the questions it reserved.
Holding
- Judicial review of the arbitrator's factual findings, contract interpretation, and remedial authority.. Courts may not overturn a labor arbitration award merely because they believe the arbitrator committed serious factual or contractual error, so long as the arbitrator is arguably construing or applying the agreement within the scope of his authority.
- Exclusion of evidence discovered after the discharge.. The arbitrator's refusal to consider evidence unknown to the employer at the time of discharge did not justify refusing to enforce the award.
- The public-policy basis for refusing enforcement of the reinstatement award.. The asserted public policy did not justify setting aside the award because it was not properly grounded in laws and legal precedents and no violation was clearly shown.
Docket 86-651
Cited authorities
- 61 Stat. 154
- 29 U.S.C. § 173
- 9 U.S.C. § 10
- 9 U.S.C. § 1
- 61 Stat. 156
- 29 U.S.C. § 185
- 29 U.S.C. § 185
- 9 U.S.C. § 10
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