Summary
The Eleventh Circuit dismissed for lack of appellate jurisdiction an interlocutory appeal from an order denying a union’s motion to compel arbitration of a dispute under a collective bargaining agreement. The court held that the Federal Arbitration Act did not apply to the relevant employment contract, the Labor Management Relations Act did not authorize interlocutory review, and the order did not qualify under the collateral-order doctrine.
Topics
Practice areas
Questions Presented
- Whether the order denying the union's motion to compel arbitration was appealable under the Federal Arbitration Act.
- Whether section 301 of the Labor Management Relations Act supplied appellate jurisdiction for the interlocutory order.
- Whether the order denying arbitration was appealable under the collateral-order doctrine.
- Whether traditional finality principles permitted an interlocutory appeal while APM's damages action remained pending.
Holdings
- The Federal Arbitration Act did not authorize an interlocutory appeal because section 1 excludes contracts of employment involving a class of workers engaged in foreign or interstate commerce, and the collective bargaining agreement governed longshoremen who load and discharge cargo for interstate transportation.
- Section 301 of the Labor Management Relations Act did not provide appellate jurisdiction over the interlocutory order denying arbitration.
- An interlocutory order denying a motion to compel arbitration under a collective bargaining agreement is not appealable under the collateral-order doctrine.
- Traditional finality principles did not permit the appeal because the order denying arbitration did not end the litigation on the merits and left substantial proceedings for the district court.
Key quotations
“Interlocutory orders declining to compel arbitration do not clear this bar.” (at 6)
“Because there is no basis for interlocutory review, we lack jurisdiction to hear this appeal.” (at 8)
“Lacking jurisdiction, we express no opinion on the merits.” (at 9)
Factual background
APM operates stevedoring facilities at the Port of Mobile, and Local 1410 represents longshore employees who load and discharge cargo for interstate transportation. Their collective bargaining agreement prohibited strikes and provided a multi-step dispute-resolution process ending in arbitration, while separately permitting certain judicial actions for equitable relief and damages. After an alleged strike, APM obtained a temporary restraining order, the strike ended, and APM pursued damages in federal court. The district court denied the union's motion to compel arbitration.
Procedural history
APM sued the union in Alabama state court for allegedly violating a collective bargaining agreement's no-strike provision after a work stoppage. The action was removed to federal district court, and APM amended its complaint to seek damages. The union moved to compel arbitration, but the district court denied the motion after concluding that the agreement permitted APM to seek monetary damages in court. The Eleventh Circuit dismissed the interlocutory appeal for lack of jurisdiction.