Boeing Co. v. International Union, United Automobile, Aerospace & Agricultural Implement Workers of America (UAW)

Summary

The Seventh Circuit affirmed an arbitration award arising from Boeing's sale of manufacturing facilities and its treatment of UAW-represented employees' pension and health benefits. The court held that the arbitrator could award damages measured by the ERISA benefits lost because of Boeing's breach of the collective bargaining agreement, notwithstanding the plan administrator's authority to decide benefit claims.

Holdings

1. The arbitrator acted within his authority by ordering a legally enforceable remedy requiring Boeing to provide the benefits to which the employees would have been entitled had Boeing complied with the collective bargaining agreement.
2. ERISA did not bar the arbitrator from awarding damages for breach of the collective bargaining agreement measured by the benefits of which Boeing's breach deprived the employees.
3. The UAW was entitled to pursue its objection to Boeing's treatment of the employees through grievance and arbitration rather than being limited to bargaining over the consequences of the plant sale.

Questions Presented

1. Whether the arbitrator exceeded his authority by ordering Boeing to provide pension and health benefits as a remedy for violating the collective bargaining agreement.
2. Whether ERISA barred the arbitrator from awarding contract damages measured by the benefits the employees would have received under Boeing's plans.
3. Whether the UAW was required to challenge Boeing's transfer of plan liabilities through collective bargaining rather than grievance arbitration.

Disposition

affirmed