Third Circuit Affirms District Court Decision to Vacate Arbitration Award
This case arises out of a dispute over a provision of a collective bargaining agreement entered into between Monongahela Valley Hospital Inc. and its employee, who was represented in the action by United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union, AFL-CIO, CLC. The union filed arbitration, pursuant to the arbitration provision in the collective bargaining agreement. The arbitrator ruled in favor of the union, and the hospital filed a complaint with the U.S. District Court for the Western District of Pennsylvania seeking to vacate the award. The district court vacated the award, and the union appealed to the U.S. Court of Appeals for the Third Circuit.
The court affirmed the district court’s decision, holding that the arbitrator’s interpretation of the disputed provision in the collective bargaining agreement (1) was a manifest disregard of the plain language of the collective bargaining agreement, (2) ignored the clear intentions of the parties, and (3) “failed to construe such provision to give effect to all parts of the provision. The court explained that the arbitrator ignored the plain language of the collective bargaining agreement when it ruled against the hospital, because its decision “flips the CBA on its head.” Additionally, the court reasoned that the arbitrator exceeded the scope of his authority when he injected a restriction into the collective bargaining agreement that was not bargained for, and was in fact rejected in a prior bargaining.