Steward Holy Family Hospital, Inc. v. Massachusetts Nurses Ass'n, No. 18-2263 (1st Cir. 2019)Annotate this Case
The First Circuit reversed the decision of the district court entering summary judgment in favor of the Steward Holy Family Hospital and vacating an award entered by an arbitrator regarding a dispute between the Hospital and the union of one of the Hospital's former nurses, Maureen Bean, holding that the arbitrator did not exceed his authority under the parties' collective bargaining agreement (CBA).
After Hospital terminated Bean her union (Union) initiated grievance procedures, arguing that there was not just cause for her termination under the CBA. The arbitrator established that Bean had engaged in misconduct providing just cause for discipline but nevertheless concluded that Bean's termination was unwarranted and ordered her reinstatement. The Hospital bought this action to vacate the award. The district court concluded that the arbitrator exceeded his authority under the CBA. The First Circuit reversed, holding that the arbitrator did not exceed the scope of his authority in ordering a lesser form of discipline in accordance with the CBA and the Hospital's own disciplinary policies.