Steelworkers Trilogy Term Paper

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Steelworkers Trilogy Cases: Their Impact on Arbitration

The steelworkers trilogy cases greatly changed the way that arbitration is dealt with in this country. Because of this it is important to discuss and analyze these three cases and determine what arbitration was like before and after the cases took place. This study looks at arbitration in various cases (most notably the steelworkers trilogy) based on unfair labor practices. There is significance to this based on the fact that the way that arbitration is conducted was changed based on these cases and they made a significant difference in the way that the laws regarding arbitration were handled.

Looked at here will be the steelworkers trilogy cases, the history of arbitration both before and after the cases, and the impact that these cases had on arbitration in this country. while there were undoubtedly many other cases that also had an impact on arbitration law, the steelworkers trilogy had the strongest impact and caused the most sweeping changes to be made within this particular area of law.

The Steelworkers Trilogy Cases: Their Impact on Arbitration


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There are several ways that parties to a labor dispute can resolve their grievances. One of the ways that is rapidly growing in popularity is arbitration. This is where the two parties get together to state and discuss their grievances before a neutral third party. They then agree to be bound by whatever that third party decides. While this seems to be a good and logical way of resolving differences, arbitration has not always been widely accepted and many people believe that there is not really enough neutrality to make arbitration work. It has also been argued that arbitration should not really be binding, since there is no court of law involved in the final decision that is made.

Term Paper on Steelworkers Trilogy Assignment

Despite this concern, however, the United States Supreme Court has indicated its belief that arbitration should be binding. The Court dealt with the importance of arbitration to the national labor policy and also worked to limit the power that courts have to interpret what is stated in collective bargaining agreements, thus allowing for arbitration to be more solid and respected. Many standards have been set by the Supreme Court to help stop lower courts from intervening when it comes to the decisions made for arbitration awards. However, there is a problem with this issue in that many of the standards that were set by the Court lack a certain degree of precision and this allows for the lower courts to reject some arbitration awards if they feel that the circumstances surrounding them were questionable. According to Professor Mack Berger, courts know that they should support the process of labor arbitration, but they also want to ensure that there is not total judicial oversight when it comes to the issue.

Arbitration Before the Steelworkers Trilogy Cases

The history of arbitration should be discussed (briefly) before the steelworkers trilogy cases, to give a clearer understanding of exactly what the cases did for this particular field of law. Overall, arbitration is used to settle disputes between people, businesses, and countries. For purposes of this discussion, however, only the arbitration that is related to labor organizations will be dealt with. Labor arbitration goes all of the way back to 1926 and the Railway Labor Act. This Act was also amended in 1936 to include the airline industry, and it is the Act that is still used today to dictate the process used for solving labor disputes within various industries, including steelwork.

Originally, it was created to ensure that the infrastructure of the railway and air industries remained intact, and also was the first piece of legislation that actually recognized the labor unions and granted them power over collective bargaining. There was a price for this, however, as the Act also prohibited any labor unions from compromising the nation's infrastructure or striking without a sanction from the government. This can cause problems for unions and workers that cannot seem to resolve their differences, and if the workers strike anyway they can be in violation of the Act and face penalties. Arbitration was designed to keep this from happening and give the labor unions a chance to work out their differences without involving the courts.

When the Act gave the labor unions collective bargaining power, it also created for them a process for formal dispute resolution. Arbitration is the final step within that process. It is used when the company and the union are completely unable to resolve their differences and settle a dispute on their own, but usually the company and union can settle their differences before arbitration is necessary. The steelworkers trilogy cases helped to ensure that arbitration was fair for all parties involved and that changes were made to the arbitration process that made it better for the future as well.

The Steelworker Trilogy Cases

The steelworkers trilogy cases of 1960 gained much attention at the time and remained famous for years afterward as being the most significant cases where the arbitration of grievances were concerned. In these cases, the United States Supreme Court was aware of the necessity of strict rules to keep arbitration honest and fair for all of the parties that are involved with it. One of the laws under which arbitration awards may be forced or vacated is Section 301 of the Labor Management Relations Act, which has been used for some time in various cases. The Federal Arbitration Act also created guidelines to ensure that arbitration is fair, and there are only four circumstances under Federal law where an arbitration award may be changed or vacated under this Act. These include:

When the award was created as a result of corruption, undue means, or fraud.

When partiality or corruption was evident on the part of the arbitrators.

When the arbitrators are found to be guilty of misconduct because they did not postpone the hearing even with a show of sufficient cause or refused to hear evidence that was material and pertinent to the case, or showed any other misconduct that violated the rights of either party to the arbitration.

When the arbitrators clearly exceeded the powers that they have or executed them so imperfectly that a definite, final, and mutual award was not actually made regarding the subject matter that was being considered.

Those that choose arbitration must be careful as well that the challenges or charges that they bring are realistic and have merit. If they do not, there can be sanctions imposed on them for the frivolous challenge to the arbitration award, or if the court must enforce a legitimate arbitration award. Overall, attorney's fees are usually what the court orders in these types of cases, but they could request other awards as well.

Case #1 - United Steelworkers of America v. American Manufacturing Co.

In this particular case, an employee, Mr. Sparks, brought an action against his employer stating that he was barred from arbitration on a particular claim. Mr. Sparks had been 25% permanently partially disabled in an accident that occurred at work, had filed for a worker's compensation claim, and the claim had been settled in a satisfactory manner. After all of this had transpired, the union that Sparks belonged to filed a grievance with the company on the grounds that Sparks should be allowed to return to his job. This was based on a seniority clause in the collective bargaining agreement. The company refused arbitration in the matter and therefore it went to court.

At the District Court level, it was decided that Sparks was not allowed to make a claim for seniority because he had accepted the terms of the settlement for the injury that he sustained. The Appeals Court used different reasoning, but it affirmed the decision of the District Court. When the case arrived at the Supreme Court through a writ of certiorari, the decision was reversed and the union that Sparks belonged to was allowed to go ahead with its claim that he should be able to return to work due to seniority. Evidence suggests that the refusal of the company to go to arbitration when this was an established policy might have had something to do with the decision that was made, since the refusal to go to arbitration violated the specific provisions that were set out in the contract between the company and the union to which Sparks belonged.

Another reason that the Court likely found that Sparks and the union could go ahead with the claim was that it was believed that the District Court lacked the jurisdiction that it needed to make a determination regarding the merits of the claim, since the parties had originally agreed to submit to a Board of Arbitrators for a decision. The Court therefore had to deal with a request that was asking that the standard form of arbitration be enforced.

Case #2 - United Steelworkers of America v. Enterprise Wheel & Car Corp.

In the Enterprise case,… [END OF PREVIEW] . . . READ MORE

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How to Cite "Steelworkers Trilogy" Term Paper in a Bibliography:

APA Style

Steelworkers Trilogy.  (2005, March 24).  Retrieved March 7, 2021, from

MLA Format

"Steelworkers Trilogy."  24 March 2005.  Web.  7 March 2021. <>.

Chicago Style

"Steelworkers Trilogy."  March 24, 2005.  Accessed March 7, 2021.