353 U.S. 448 (1957)
In 1953 the Textile Workers Union of America entered into a collective bargaining agreement with Lincoln Mills of Alabama.1 The agreement was to run for one year and from year to year thereafter unless terminated on specified notices.2 It contained a no-strike clause and established a multi-step grievance procedure whose final step, available to either party, was arbitration.3
Several grievances concerning work loads and work assignments arose under the agreement.4 The union processed the grievances through every step of the contractual procedure, after which the employer denied them.5 The union then requested arbitration, but the employer refused.6
The union filed suit in federal district court seeking an order compelling the employer to arbitrate the grievances.7 The district court held that it possessed jurisdiction and directed the employer to comply with the arbitration provisions of the agreement.8 On appeal the Court of Appeals reversed by a divided vote, concluding that the district court lacked authority under either federal or state law to grant the requested relief.9
The Supreme Court granted certiorari.10 After the Court of Appeals decision but before oral argument, Lincoln Mills terminated its operations, ceased all work at the mill in March 1957, and contracted to sell its mill properties.11 Some of the grievances sought back pay for increased workloads, and the collective bargaining agreement authorized the arbitration board to adjust compensation retroactively.12
Whether section 301(a) of the Labor Management Relations Act of 1947 authorizes federal district courts to compel specific performance of arbitration provisions in collective bargaining agreements?13
Yes. The Textile Workers Union of America entered into a collective bargaining agreement with Lincoln Mills of Alabama in 1953 that contained a no-strike clause and a grievance procedure culminating in arbitration available to either party.16 The union processed several grievances concerning work loads and work assignments through every step of the procedure, after which the employer denied them, and the union requested arbitration which the employer refused.17 The district court held it had jurisdiction and ordered compliance with the arbitration provisions, but the court of appeals reversed.18 Legislative history demonstrates that Congress viewed the agreement to arbitrate as the quid pro quo for the no-strike clause and intended federal courts to enforce such agreements to promote industrial peace.19
The policy expressed in the Act therefore requires that the arbitration promise be specifically enforced rather than reading section 301(a) as conferring jurisdiction only.20
Section 301(a) authorizes federal district courts to compel specific performance of arbitration provisions in collective bargaining agreements.21
Related opinions on this issue
Justice Burton concurred in the result. He agreed that the district court possessed jurisdiction over the union controversy and was not powerless to fashion an appropriate federal remedy for specific performance of the collectively bargained arbitration agreement.22 That power finds its source in section 301 itself together with the inherent equitable powers of a federal district court, nurtured by congressional policy favoring labor arbitration in industries affecting commerce.23
He did not join the majority's conclusion that substantive law under section 301 must be federal law.24
Whether federal law governs suits brought under section 301(a) of the Labor Management Relations Act of 1947?25
The substantive law to apply in suits under section 301(a) is federal law which the courts must fashion from the policy of national labor laws.26 State law may be resorted to if compatible with the purpose of section 301 but is absorbed as federal law and is not an independent source of private rights.27
Yes. In suits under section 301(a) the substantive law is federal law fashioned from the policy of national labor laws.28 The Labor Management Relations Act supplies some substantive rules while other problems are solved by looking to the policy of the legislation and fashioning a remedy that effectuates that policy.29 Federal interpretation governs, though compatible state law may be used and then absorbed as federal law.30
This approach avoids any constitutional difficulty because a case arising under section 301(a) falls within the judicial power under Article III as a case arising under the laws of the United States.31
Federal law governs suits brought under section 301(a) of the Labor Management Relations Act of 1947.32
Related opinions on this issue
Joined by Justice Harlan
Justice Frankfurter dissented. He maintained that section 301 is a plainly procedural provision that merely affords an accessible federal forum for suits on agreements between labor organizations and employers without enacting federal substantive law for such suits.33 He argued that the majority's attribution of occult substantive content to the section rests on an alchemy of construction unsupported by the legislative history, which he appended in full, and that the decision creates vast problems of conflict between state and federal law that Congress never considered.34
Whether the Norris-LaGuardia Act withdraws federal court jurisdiction to compel arbitration of grievance disputes arising under collective bargaining agreements?35
The Norris-LaGuardia Act does not withdraw federal court jurisdiction to compel arbitration of grievance disputes.36 The failure to arbitrate was not among the abuses the Act targeted.37 Section 8 of the Act itself favors voluntary arbitration.38 The clear congressional policy favoring enforcement of arbitration agreements under section 301(a) precludes restricting that section to damage suits subject to Norris-LaGuardia procedures.
No. The Norris-LaGuardia Act does not withdraw jurisdiction to compel arbitration under section 301(a).39 The procedural requirements of section 7 for injunctions in labor disputes do not apply because the failure to arbitrate was not part of the abuses against which the Act was aimed.40 Section 8 indicates a congressional policy toward settlement by arbitration, and prior decisions confirm that Norris-LaGuardia does not bar enforcement of federal mandates in analogous labor statutes.41
The congressional policy in favor of enforcing agreements to arbitrate grievance disputes is therefore not subjected to the requirements of section 7.42
The Norris-LaGuardia Act does not withdraw federal court jurisdiction to compel arbitration of grievance disputes arising under collective bargaining agreements.43