Associated Electric Coop. v. IBEW, No. 12-3712 (8th Cir. 2014)
Annotate this CaseAECI filed suit against the Union seeking to vacate the arbitrator's award and the Union counterclaimed for enforcement. Relying on the court's decision in Coca-Cola Bottling Co. v. Teamsters Local Union No. 688, the district court ruled that the last chance agreement (LCA) superseded the collective bargaining agreement and therefore, when the arbitrator ignored the clear and unambiguous terms of the LCA, he imposed his personal standards of industrial justice. The court concluded that the district court read the Coca-Cola bottling decision too broadly. Where a CBA requires "just cause" to discipline or discharge an employee but fails to define the term, the arbitrator's broad authority to interpret the contract, to which the court must defer, includes defining and applying that term of the contract. Viewed from this perspective, the arbitrator's decision to sustain the Union's grievance must be enforced. Because the arbitrator specifically invoked and applied the just cause provision of the CBA, the contract between AECI and the Union that defined his authority, his decision "draws its essence" from the CBA. Accordingly, the arbitrator's decision sustaining the Union's grievance must be enforced. The court declined to enforce the portion of the award granting the employee back pay from the day he was suspended until the day he was discharged. The court reversed and remanded.
Court Description: Civil case - Labor law. In concluding that the arbitrator was obligated to enforce a mandatory termination provision in a "Last Chance Agreement," the district court read this court's decision in Coca-Cola Bottling Co. v. Teamsters Local Union No. 688, 959 F.2d 1438 (8th Cir. 1992), cert. denied, 506 U.S. 1013 (1992) too broadly; since the company and the employee entered into the Agreement by mutual mistake, it was within the arbitrator's just cause discretion to conclude the employee's conduct did not fall within the unyielding remedial terms of the Agreement; however, because the union grieved the employee's discharge rather than his earlier suspension, the court would not enforce the part of the arbitrator's award which granted the employee back pay from the day he was suspended until the date he was discharged. Judge Colloton, concurring in the judgment and dissenting in part.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.