Silgan Containers Corp. v. Sheet Metal Workers Int'l, No. 15-1956 (8th Cir. 2016)
Annotate this CaseSilgan and the Union challenge an arbitration award. The district court granted summary judgment in favor of Silgan and the Union appealed. The court concluded that the question of validity and formation is not within the scope of the arbitration agreement. Because the arbitrator lacked authority to decide this issue, the district court did not err in vacating the award. Furthermore, the district court erred in granting summary judgment to Silgan and rescinding Article 36 where the mistake has resulted solely from the negligence or inattention of the party seeking relief, and the other party is without fault. Accordingly, the court affirmed in part, reversed in part, and remanded.
Court Description: Benton, Author, with Murphy and Smith, Circuit Judges] Civil case - Arbitration. The question of the validity and formation of a labor contract was not within the scope of the parties' arbitration agreement, and the district court did not err in vacating the arbitrator's award because the arbitrator lacked authority to decide this issue; the district court erred in granting the employer's motion for summary judgment rescinding a provision of the agreement, as any mistake regarding adoption of the contract provision was solely the result of the employer's inattention or negligence and the mistake could not serve as the basis for relief. [ April 14, 2016
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