Sheet Metal Employers Indus. Promotion Fund v. Absolut Balancing Co., Inc.

Multi-employer funds established by a collective bargaining agreement (CBA) between the Sheet Metal and Air Conditioning Contractor National Association and the Sheet Metal Worker’s Union sought confirmation of arbitration awards granted against five employers. None of the employers had participated in the arbitration, which concerned contributions to the funds. The district court declined to confirm the award, concluding that there was an open question as to whether the employers were party to the CBA, and, therefore, bound to its arbitration procedures. After initially ruling that state law applied to the question of whether the employers were bound to arbitrate under the CBA, the court certified a question for appeal pursuant to 28 U.S.C. 1292(b): whether state or federal law will apply at trial to the question of whether the employers “are bound/signatory to” the CBA? The Sixth Circuit reversed. While state contract law may provide helpful guideposts to federal courts, it is well-established that in the field of labor relations, the technical rules of contract law do not determine the existence of a CBA. The law to be applied to the question of whether a party has assented to the terms of a CBA, including an arbitration provision, is ultimately federal. View "Sheet Metal Employers Indus. Promotion Fund v. Absolut Balancing Co., Inc." on Justia Law