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Keywords

contractjurisdictionarbitrationcorporationarbitration clause
contractjurisdictionarbitrationinjunctionhearingcorporationdeclaratory judgment

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Kansas City Royals Baseball Corp. v. Major League Baseball Players Ass’n, 532 F.2d 615, 78 Lab.Cas. P 11,302

Facts

The Kansas City Royals Baseball Corporation and other Major League Baseball teams sought to set aside an arbitration panel's award that granted free agent status to players Andy Messersmith and Dave McNally after they completed their renewal years. The arbitration panel determined that the players were free agents and directed the teams to remove them from their reserve lists. The teams argued that the grievances were non-arbitrable under the collective bargaining agreement, which they claimed excluded disputes regarding the reserve system.

The arbitration panel set the matter for hearing. Thereafter, on October 28, 1975, the Kansas City Royals Baseball Corporation commenced an action in the United States District Court for the Western District of Missouri seeking a declaratory judgment that the aforesaid grievances were non-arbitrable and an injunction prohibiting the Players Association from proceeding with arbitration.

Issue

Whether the arbitration panel had jurisdiction to determine the grievances of Messersmith and McNally regarding their free agent status under the collective bargaining agreement.

Whether the arbitration panel had jurisdiction to determine the grievances of Messersmith and McNally regarding their free agent status under the collective bargaining agreement.

Rule

A party may be compelled to arbitrate a grievance only if it has agreed to do so; the question of arbitrability is one of contract construction for the courts. Grievances under a collective bargaining agreement providing for arbitration must be deemed arbitrable unless it can be positively assured that the arbitration clause does not cover the dispute. A broad arbitration provision may exclude a grievance only if the agreement contains an express exclusion or if there is strong evidence of intent to exclude the grievance from arbitration.

A party may be compelled to arbitrate a grievance only if it has agreed to do so; the question of arbitrability is thus one of contract construction and it is for the courts to decide.

Analysis

The court found that the arbitration provision in the collective bargaining agreement was broad enough to encompass the grievances of Messersmith and McNally. The history of negotiations did not provide sufficient evidence to overcome the presumption of arbitrability. The court determined that the arbitration panel's interpretation of the agreement was reasonable and that the grievances were arbitrable despite the teams' claims regarding the reserve system.

We begin with the proposition that the language of Article X of the 1973 agreement is sufficiently broad to require arbitration of the Messersmith-McNally grievances. We think this clear because the disputes involve the interpretation of the provisions of agreements between a player or the Players Association and a club or the Club Owners.

Conclusion

The court affirmed the district court's order enforcing the arbitration panel's award, concluding that the panel had jurisdiction and that its decision was consistent with the collective bargaining agreement.

We hold that the arbitration panel had jurisdiction to resolve the dispute, that its award drew its essence from the collective bargaining agreement, and that the relief fashioned by the District Court was appropriate.

Who won?

The Major League Baseball Players Association prevailed in this case as the court upheld the arbitration panel's decision granting free agent status to players Messersmith and McNally. The court found that the arbitration panel had the authority to interpret the collective bargaining agreement and that the grievances were arbitrable. The ruling reinforced the players' rights under the agreement and established the validity of the arbitration process in resolving disputes related to player contracts.

The Major League Baseball Players Association prevailed in this case as the court upheld the arbitration panel's decision granting free agent status to players Messersmith and McNally.

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