United Natural Foods, Inc. v. Teamsters Local 414, No. 22-1469 (7th Cir. 2023)
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A collective bargaining agreement (CBA), covered employees at United’s Indiana distribution center, prohibiting strikes and lock-outs during the life of the agreement. Negotiations over a successor agreement were ongoing when the existing agreement expired in September 2019. The agreement provided: So long as negations are ongoing, all terms and provisions of the existing CBA will continue to apply. However, “[i]n the event of a strike, the provisions of this section do not apply.” Bargaining over a new agreement came to a standstill on September 20. On December 12, Local 414 went on strike with a picket line at the Indiana facility. On December 17, Local 414 began additional picketing at United’s Minnesota and Wisconsin distribution centers. Workers there walked off the job. On December 18, Local 414 ended the strike and ceased picketing at the other sites. In July 2020, Local 414 engaged in another strike in Indiana.
United filed suit under the Labor Management Relations Act, 29 U.S.C. 185, alleging that the strikes violated the CBA’s no-strike provisions. Local 414 moved to compel arbitration of the claim. The Seventh Circuit affirmed that the claims were not subject to arbitration. The arbitration procedure is focused exclusively on employee-initiated grievances and does not apply to employer-initiated grievances. The arbitration clause is not reasonably susceptible to an interpretation that includes an employer-initiated dispute regarding the CBA’s terms.
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