Exide Technologies v. International Brotherhood of Electrical Workers, No. 19-2317 (8th Cir. 2020)
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This appeal stemmed from a collective bargaining agreement (CBA) dispute between the parties where an arbitrator resolved the dispute in favor of the union. The Eighth Circuit held that because the arbitrator was arguably construing or applying the contract and acting within the scope of his authority, there is no basis for vacating the arbitrator's finding that Exide violated the CBA.
The court also held that the district court correctly determined that it did not have jurisdiction over Exide's claim that the arbitrator's decision that unilaterally changing Family Medical Leave Act leave administrators was a material, substantial and significant change in the employees' terms and conditions of employment in violation of Section 8 of the National Labor Relations Act. Rather, Congress has empowered the NLRB to resolve unfair-labor-practice claims in the first instance. Furthermore, the cases cited by the parties do not expand the court's original jurisdiction.
Court Description: [Kelly, Author, with Melloy and Kobes, Circuit Judges] Civil case - Labor law. The arbitrator's decision that Exide violated the parties' Collective Bargaining Agreement by unilaterally changing FMLA leave administrators did not exceed the arbitrator's authority and was a reasonable interpretation of the relevant CBA provisions; the district court correctly determined it did not have jurisdiction over Exide's claim that the arbitrator's decision that unilaterally changing FMLA leave administrators was a material, substantial and significant change in the employees' terms and conditions of employment in violation of Section 8 of the NLRA; such a claim is an unfair-labor-practice claim which Congress has empowered the NLRB to decide in the first instance; nor does this court have original jurisdiction to decide if Exide violated the NLRA.
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