Summary
The Seventh Circuit affirmed the district court's denial of the employer's motion to vacate an arbitrator's award interpreting a collective bargaining agreement's "Act of God" provision during the pandemic. The court emphasized that federal labor law requires courts to uphold arbitrators' interpretations of contracts as long as they are not disregarding the agreement or acting corruptly. Additionally, the court criticized the appellant for inconsistent corporate naming in its filings and ordered it to show cause why sanctions should not be imposed.
Topics
Practice areas
Questions Presented
- Whether the district court erred in refusing to vacate the arbitration award under the Federal Arbitration Act
- Whether the phrase “Act of God” in the collective bargaining agreement includes governmental orders issued in response to the pandemic
Holdings
- The judgment of the district court is affirmed; an arbitrator’s interpretation of a contract is conclusive and not subject to judicial review absent fraud, corruption, or an illegal award.
- The phrase does not include governmental orders; the arbitrator correctly interpreted it to cover only natural events such as floods or tornadoes.
Key quotations
“As we have said too many times to want to repeat again, the question for decision by a federal court asked to set aside an arbitration award … is not whether the arbitrator or arbitrators erred in interpreting the contract; it is not whether they clearly erred in interpreting the contract; it is not whether they grossly erred in interpreting the contract; it is whether they interpreted the contract.” (at 5)
“The judgment of the district court is affirmed.” (at 5)
Factual background
The parties' collective bargaining agreement guaranteed a minimum of 40 paid hours per week to employees in the top 80% of the seniority list. During the early COVID‑19 pandemic the employer's senior employees worked only about 30 hours per week, and the union argued the employer must honor the 40‑hour floor. The arbitrator held that the contract's "Act of God" exception did not cover the Governor’s pandemic orders, and therefore the employer must provide the hours. The employer sought judicial review of the award.
Procedural history
The district court declined to vacate the arbitrator's award interpreting the collective bargaining agreement; the appellant appealed that decision.