ABF Freight System, Inc. v. Int'l Brotherhood of Teamsters, et al., No. 12-3090 (8th Cir. 2013)
Annotate this CaseABF filed suit against defendants alleging a violation of a collective bargaining agreement (CBA). On appeal, ABF challenged the district court's grant of defendants' motion to dismiss under Rule 12(b)(6). ABF contended that because the agreement's grievance-resolution system was unavailable, the district court may appoint a disinterested tribunal to hear the grievance or, alternatively to provide redress. The court concluded that the district court could not appoint a new tribunal because the National Grievance Committee (NGC) rules provided a solution. Though the rules here did not mandate the NGC's specific response to a disqualification, they nonetheless made clear that resolving it by amending or modifying the rules was an issue for the NGC. In regards to ABF's request for redress directly from the court for breach of the National Master Freight Agreement (NMFA), the court rejected ABF's unavailability and futility arguments, as well as its remaining claims. Accordingly, the court affirmed the judgment of the district court.
Court Description: Civil case - Labor law. For the court's prior opinion in the matter, see ABF Freight Systems, Inc. v. Int'l Bhd. of Teamsters, 645 F.3d 954 (8th Cir. 2011). The district court did not err in denying ABF's request to appoint a disinterested tribunal to hear its grievance as the rules of the National Grievance Committee provide a solution for the conflict ABF alleges precludes the Committee from hearing the grievance and any action for modifying the rules on this question is an issue for the Committee; the district court correctly determined that it could not rule directly on ABF's claim that the National Master Freight Agreement had been violated based on ABF's argument that the grievance resolution process was not available or futile; nor did defendants waive the grievance procedure and elect to pursue the matter in court as their initial motions to dismiss did not substantially invoke the litigation machinery.
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