District No. 1 v. Liberty Maritime Corp., No. 18-7148 (D.C. Cir. 2019)Annotate this Case
MEBA filed suit against Liberty, alleging that its contract with Liberty required the parties to submit the underlying dispute to arbitration. The district court ruled in favor of MEBA and granted judgment on the pleadings, compelling arbitration.
The DC Circuit affirmed and held that the district court had jurisdiction over MEBA's claim under section 301 of the Labor Management Relations Act of 1947 (LMRA), which provides federal jurisdiction over suits for violation of contracts between an employer and a labor organization. In this case, MEBA's claims regarding the arbitrability of the dispute clearly fell within the district court's statutory jurisdiction. The court rejected Liberty's argument under the Garmon preemption doctrine, and held that federal courts retain jurisdiction over hybrid claims raising both contractual and representational issues. Finally, although jurisdiction was proper here, the court reversed and remanded because material facts remained in dispute regarding the existence of an applicable arbitration clause.