Major League Baseball Players Association v. Steve Garvey

Steve Garvey, a former baseball player, moved to vacate the arbitrator’s decision. The district court denied this motion and Mr. Garvey appealed. The Ninth Circuit Court of Appeals reversed and remanded. The district court in turn remanded to the arbitration panel and the player appealed. The Ninth Circuit reversed and remanded with instructions to remand to the arbitration with instructions to enter an award for the player in the amount claimed. The supreme court reversed and remanded.

The court noted that federal courts are not authorized to review labor arbitration decisions on the merits despite allegations that the decision rests on factual errors or misinterprets the parties collective bargaining agreement. It is only when an arbitrator strays from the interpretation and application of the collective bargaining agreement and effectively dispenses his own brand of industrial practice that the decision may be unenforceable.

On the other hand, if there is no arbitrator dishonesty, arbitration decisions that are improvident, irrational, or contains silly fact finding provides no basis for a reviewing court to refuse to enforce the award. Similarly, even serious error on the arbitrator’s part does not justify overturning the decision when the arbitrator is construing a labor contract and acting within the scope of authority. If an arbitrator’s award may be properly vacated under these standards, the appellate remedy is to remand for further arbitration proceedings.