Union Internacional, UAW Local 2415 v. Bacardi Corp., No. 20-1136 (1st Cir. 2021)Annotate this Case
The First Circuit affirmed the judgment of the district court summarily affirming an arbitration award dismissing Union Interacional UAW, Local 2415's wage grievance claim against Bacardi Corporation, holding that the Union did not identify an error in the arbitration award so egregious as to permit this Court to vacate it.
The arbitrator found that the Union's claim was not procedurally arbitrable because the Union failed to comply with the contractual wage grievance procedure. On appeal, the Union argued that either the arbitrator should have deemed the procedural arbitrability defect waived or that the procedural defect did not justify dismissing the entire claim. The First Circuit affirmed, holding that, while the Union's waiver arguments had merit, the arbitrator acted within the scope of his authority in dismissing the entire claim for lack of procedural arbitrability.
This opinion or order relates to an opinion or order originally issued on August 9, 2021.