Collective Bargaining Act Ratification Date Was For District Court To Resolve
Granite Rock Co. v. Int'l. Brotherhood of Teamsters, No. 08-1214, an action against a labor union by an employer, invoking federal jurisdiction under section 301(a) of the Labor Management Relations Act (LMRA), seeking strike-related damages for the unions' alleged breach of contract, and asking for an injunction against the ongoing strike because the hold-harmless dispute was an arbitrable grievance under the new collective bargaining agreement (CBA). The Court affirmed in part the Ninth Circuit's partial affirmance of the district court's order dismissing plaintiff's tortious interference claims and denying defendant's separate motion to send the parties' dispute over the CBA's ratification date to arbitration, holding that the Ninth Circuit did not err in declining to recognize a new federal common-law cause of action under LMRA section 301(a) for defendant's alleged tortious interference with the CBA. However, the Court reversed in part, holding that the parties' dispute over the CBA's ratification date was a matter for the district court, not an arbitrator, to resolve.
As the Court wrote: "This case involves an employer's claims against a local union and the union's international parent for economic damages arising out of a 2004 strike. The claims turn in part on whether a collective-bargaining agreement (CBA) containing a no-strike provision was validly formed during the strike period. The employer contends that it was, while the unions contend that it was not. Because the CBA contains an arbitration clause, we first address whether the parties' dispute over the CBA's ratification date was a matter for the District Court or an arbitrator to resolve. We conclude that it was a matter for judicial resolution. Next, we address whether the Court of Appeals erred in declining the employer's request to recognize a new federal cause of action under §301(a) of the Labor Management Relations Act, 1947 (LMRA), 61 Stat.156, 29 U. S. C. §185(a), for the international union's alleged tortious interference with the CBA. The Court of Appeals did not err in declining this request."
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