International Union v. Trane U.S. Inc., No. 19-2255 (8th Cir. 2020)
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The Eighth Circuit reversed the district court's dismissal of the union's claims against Trane concerning an arbitration award. In this case, the June Award indicated that the arbitrator did not intend for it to be final because he explicitly retained jurisdiction "until the terms of the award are met." When a dispute did arise regarding damages, the arbitrator resolved that dispute in the September Award and then expressly stated that he was "no longer retaining jurisdiction in this matter." Therefore, the express relinquishment of jurisdiction in the September Award indicated that the arbitrator intended the September Award to be final and did not contemplate further disputes regarding the award.
The court held that the union is not time-barred from seeking to vacate the arbitration award because the text of the June Award indicates that it was not the final award. The court stated that the September Award is the final award and the union filed its claim to vacate within 90 days of it. Therefore, the union's claim was timely and the district court erred in concluding otherwise. The court remanded for further proceedings.
Court Description: [Kelly, Author, with Melloy and Kobes, Circuit Judges] Civil case - Arbitration. In a dispute over whether Trane's Fort Smith plant employees were entitled to vacation time when the plant was closed, an arbitrator concluded Trane violated the CBA and the parties' closing agreement when it denied the employees vacation pay and unused sick leave (the June award); Trane interpreted the arbitrator's award in a way that only three employees qualified for payments, while the union contended approximately 200 employees were eligible for payments; when presented with the issue, the arbitrator sent an email stating Trane's actions complied with the award (the September award). The union brought an action to compel further arbitration or to vacate the final arbitration award; the district court dismissed the action, concluding the June award was final, and the union was untimely in seeking to vacate the award; the district court further concluded the union could not compel further arbitration because the arbitrator had considered the issue in making the award; held, the text of the June award indicates it was not final as the arbitrator expressly retained jurisdiction until the terms of the award were met and any issues or disputes were resolved; the subsequent September email was thus the final award as the arbitrator expressly relinquished further jurisdiction; as a result, the district court erred in finding the union action was untimely; remanded for further proceedings. Judge Kobes, dissenting.
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