International Union v. Trane U.S. Inc., No. 18-3110 (8th Cir. 2020)
Annotate this Case
The union appealed the district court's order denying the union's motion to compel arbitration of the grievances regarding early retirement benefits for employees terminated as the result of a plant closing.
Applying de novo review, the Eighth Circuit held that the grievance, on its face, stated a claim that Trane violated a specific provision of the collective bargaining agreement (CBA) by not providing a bargained-for benefit, a benefit Trane reconfirmed in the Memorandum of Agreement. The court held that this grievance involved the interpretation of the CBA and was therefore arbitrable. Accordingly, the court reversed the district court's judgment as to the bridge grievance. However, the court affirmed the order denying the union's motion to compel arbitration of the temporary pension supplement benefit grievance, holding that it was not arbitrable because it was governed by the Employee Retirement Income Security Act, rather than the Labor Management Relations Act or the CBA. The panel remanded for further proceedings.
Court Description: Loken, Author, with Colloton and Kobes, Circuit Judges] Civil Case - Labor. On appeal from denial of the motion to compel arbitration of two grievances over denial of two benefits due eligible employees after a plant closure. As for the Bridge Benefit, a bargained-for benefit, the grievance concerned access to and the timing of retirement benefits and is thus arbitrable. The Temporary Pension Supplement Benefit was provided in the Summary Plan Description, the terms of which are governed by ERISA, not the Labor Management Relations Act or the collective bargaining agreement and thus are not arbitrable. Judge Colloton, concurs in part and dissents 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.