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Keywords

contractsettlementbreach of contractjurisdictiondamagesappealtrialtestimonymotionarbitratorjudicial review
contractlawsuitbreach of contractjurisdictionappealtrialarbitrator

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Garvey v. Roberts, 203 F.3d 580, 163 L.R.R.M. (BNA) 2449, 140 Lab.Cas. P 10,643, 00 Cal. Daily Op. Serv. 1090, 2000 Daily Journal D.A.R. 1611

Facts

Steve Garvey, a former professional baseball player, sought to vacate an arbitrator's decision that denied his claim for damages from a settlement fund established due to collusion among baseball clubs in the free-agent market. The Major League Baseball Players Association had previously confirmed the denial of Garvey's claim, which was based on an alleged lost contract extension for the 1988 and 1989 seasons. Garvey argued that the arbitrator improperly applied the rules governing the claims process and failed to consider evidence supporting his claim. The district court denied Garvey's motion, leading to his appeal.

Issue

Whether the district court had jurisdiction to hear Garvey's motion to vacate the arbitrator's decision and whether the arbitrator's decision was valid under the applicable legal standards.

Whether the district court has jurisdiction over a matter is reviewed de novo.

Rule

Jurisdiction under the Labor Management Relations Act (LMRA) is proper when the suit is based on an alleged breach of contract between an employer and a labor organization, and the resolution is governed by the terms of that contract. Judicial review of an arbitrator's decision in labor disputes is limited, and an arbitrator's award can only be overturned if it is clear that the arbitrator did not base his decision on the collective bargaining agreement or followed his own biases.

Jurisdiction is proper under the LMRA section governing suits by and against labor organizations where: (1) the suit is based on an alleged breach of contract between an employer and a labor organization, and (2) the resolution of the lawsuit is focused upon and governed by the terms of the contract.

Analysis

The court found that Garvey's claim arose from the collective bargaining agreement and the subsequent settlement agreement, thus establishing jurisdiction under the LMRA. The arbitrator's decision was scrutinized under the standard that it could only be overturned if it did not draw its essence from the collective bargaining agreement. The court determined that the arbitrator had dispensed his own brand of industrial justice by disregarding the evidence presented by Garvey and favoring contradictory testimony from a club owner, which led to the conclusion that the arbitrator's decision was not valid.

In the present case, accepting Arbitrator Roberts's reasons as the basis for the award leads us inexorably to the conclusion that in reaching his decision the arbitrator 'dispensed his own brand of industrial justice.'

Conclusion

The Court of Appeals reversed the district court's decision and remanded the case, holding that the arbitrator had improperly confirmed the denial of Garvey's claim for damages.

Reversed and remanded.

Who won?

Steve Garvey prevailed in his appeal against the Major League Baseball Players Association. The court found that the arbitrator had failed to properly apply the established framework for evaluating claims and had instead relied on his own biases, which warranted the reversal of the decision. The court emphasized that the evidence presented by Garvey, particularly the testimony regarding the alleged contract extension, was not adequately considered by the arbitrator, leading to an unjust denial of his claim.

Steve Garvey prevailed in his appeal against the Major League Baseball Players Association. The court found that the arbitrator had failed to properly apply the established framework for evaluating claims and had instead relied on his own biases, which warranted the reversal of the decision.

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