Union Pacific R. Co. v. Locomotive Engineers (2009)

Docket
08-604
Decided
2009-01-01

Summary

Question: 1) Did the Seventh Circuit err in setting aside a final arbitration award for an alleged due process violation? 2) Are prearbitration settlement conferences a prerequisite for NRAB jurisdiction over a dispute? Conclusion: Yes and No. With Justice Ruth Bader Ginsburg writing for a unanimous bench, the Court held that the Seventh Circuit effectively resolved the Union's core complaint, but erred in doing so under a "constitutional, rather than statutory headline." The Court reasoned that there was no due process issue "alive" in the case. The Court further held that prearbitration settlement conferences are not a prerequisite for NRAB jurisdiction over a dispute. The Court reasoned that prearbitration conference requirements set out by the NRAB run independent of the collective bargaining process and do not bear on the merits of an actual grievance.

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