SEIU v. Los Robles Reg'l Med. Ctr., No. 13-55672 (9th Cir. 2015)
Annotate this CaseThe Union appealed the district court's grant of summary judgment to the Medical Center and dismissal of the Union's petition to compel arbitration. At issue was when the Union requested arbitration, and when the Medical Center unequivocally and expressly rejected that request. The court held that it is a breach of the duty of good faith performance under Section 301 of the Labor Management Relations Act, 29 U.S.C. 185, for an employer to fail to respond within a reasonable time to a union’s communication which seeks to abide by a grievance process set forth in a collective bargaining agreement. In this case, it was not reasonable for the Medical Center to wait in silence for more than five months following the Union’s letter demanding arbitration, and then claim in litigation that the Union missed the statute of limitations. The Medical Center's delay of five months is a length of time nearly as long as the six months statute of limitations itself. Accordingly, the court reversed and remanded in part, and vacated in part.
Court Description: Labor Law. The panel reversed the district court’s summary judgment and vacated its order dismissing a petition to compel arbitration under Section 301 of the Labor Management Relations Act. Service Employees International Union, United Healthcare Workers-West, and Los Robles Regional Medical Center were parties to a collective bargaining agreement. The Union sought arbitration of a grievance objecting to the Medical Center’s reorganization of its engineering department. The panel held that the Union’s petition to compel arbitration was not barred by Section 301’s six-month statute of limitations because the limitation period did not begin to run until the Medical Center officially replied to the Union’s letter demanding arbitration. Reading the record in the light most favorable to the Union, the non-moving party, the panel concluded that an earlier email from the Medical Center did not “make it clear” that the Medical Center refused to arbitrate because the Union did not request arbitration until after the email was sent. The panel concluded that the Medical Center’s delay in responding to the Union’s letter demanding arbitration must be considered a violation of good faith because the five-month delay was a period of time nearly equal to the entire six-month limitation period. SEIU V. LOS ROBLES REG’L MED. CTR. 3 The panel reversed the district court’s grant of summary judgment and remanded for further proceedings. It vacated the district court’s award of costs for reconsideration in light of the reversal of summary judgment.
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