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.