Summary
The Third Circuit held that a dispute over whether Mitchell Transport, as successor to Martin Trucking, was bound by a prior arbitration award was arbitrable under the broad arbitration clause in the collective bargaining agreement. The court concluded that the district court lacked jurisdiction to decide the merits and should have stayed the proceedings pending arbitration. It vacated the district court’s judgment and remanded with instructions to stay further proceedings.
Holdings
- The dispute was arbitrable under the broad arbitration clause in the collective bargaining agreement Mitchell signed.
- The district court lacked jurisdiction to adjudicate the merits or enforce JAC 1108 against Mitchell before the parties arbitrated whether Mitchell was bound by the award.
- Under the circumstances presented, the district court should not have relied on the successorship doctrine because Mitchell had expressly assumed the collective bargaining agreement and its arbitration clause provided an appropriate means of resolving the dispute.
Questions Presented
- Whether the dispute over Mitchell's obligation to comply with JAC 1108 was arbitrable under the broad arbitration clause in the collective bargaining agreement.
- Whether the district court had jurisdiction to enforce against Mitchell, before arbitration, an award issued against Martin.
- Whether the successorship doctrine independently authorized the district court to impose JAC 1108 on Mitchell.
Disposition
vacated
Cases Cited (20)
- Steelworkers v. American Mfg. Co., 363 U.S. 564, 80 S. Ct. 1343, 4 L. Ed. 2d 1403 (1960)(followed)
- Steelworkers v. Warrior & Gulf Co., 363 U.S. 574, 80 S. Ct. 1347, 4 L. Ed. 2d 1409 (1960)(followed)
- Steelworkers v. Enterprise Corp., 363 U.S. 593, 80 S. Ct. 1358, 4 L. Ed. 2d 1424 (1960)(followed)
- Atkinson v. Sinclair Refining Co., 370 U.S. 238, 241, 82 S. Ct. 1318, 1320, 8 L. Ed. 2d 462 (1961)(followed)
- Westinghouse Broadcasting v. Local 804, International Alliance, 616 F.2d 97, 98 (3d Cir. 1980)(followed)
- Bechtel Corp. v. Local 215, Laborers’ International Union, 544 F.2d 1207, 1212 (3d Cir. 1976)(followed)
- Teamsters Local Union No. 30 v. Helms Express, Inc., 591 F.2d 211 (3d Cir.), cert. denied, 444 U.S. 837 (1979)(followed)
- Howard Johnson Co. v. Hotel Employees, 417 U.S. 249, 257, 262-63 n. 9, 94 S. Ct. 2236, 2241, 2243-44, 41 L. Ed. 2d 46 (1974)(distinguished)
- Golden State Bottling Co. v. NLRB, 414 U.S. 168, 181, 184, 94 S. Ct. 414, 423, 425, 38 L. Ed. 2d 388 (1973)(distinguished)
- NLRB v. Burns Security Services, 406 U.S. 272, 287-88, 92 S. Ct. 1571, 1582, 32 L. Ed. 2d 61 (1972)(followed)
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