Mary Ellen Wedding v. The University of Toledo
89 F.3d 316, 152 L.R.R.M. (BNA) 2881, 1996 U.S. App. LEXIS 17525 (1996)
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Rule of Law:
When a collective bargaining agreement contains an arbitration clause, a court must defer to the arbitral process and should not rule on the legality of a contractual provision before an arbitrator has had the opportunity to first interpret and apply the agreement's terms.
Facts:
- Dr. Wedding, a tenured professor at the University of Toledo, believed the University was paying her less than her less-qualified male colleagues.
- The University and the professors' union were parties to a Collective Bargaining Agreement (CBA) that provided for an internal grievance procedure to resolve disputes.
- Article 19.10 of the CBA stipulated that if an employee filed a lawsuit or sought relief from an outside administrative forum, the internal grievance process would be held in abeyance (paused).
- Wedding filed an internal grievance with the University alleging sex-based wage discrimination under the CBA.
- Subsequently, Wedding filed a sex discrimination lawsuit against the University in federal court.
- Upon receiving notice of the lawsuit, the University, citing Article 19.10 of the CBA, suspended its processing of Wedding's internal grievance.
Procedural Posture:
- Wedding filed a sex discrimination action against the University of Toledo in the U.S. District Court for the Northern District of Ohio.
- Within that action, Wedding filed a motion to stay the court proceedings and compel the University to utilize its internal grievance system, arguing that the CBA provision pausing grievances was illegal.
- The district court granted Wedding's motion, finding Article 19.10 of the CBA to be illegal.
- The district court issued an order staying its own proceedings and compelling the University to resume processing Wedding's grievance.
- The University of Toledo, as appellant, appealed the district court's order to the U.S. Court of Appeals for the Sixth Circuit.
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Issue:
Should a federal court decide the substantive legality of a provision in a collective bargaining agreement before an arbitrator has had the opportunity to interpret and apply the agreement's terms?
Opinions:
Majority - Judge Bailey Brown
No, a federal court should not decide the substantive legality of a provision in a collective bargaining agreement before an arbitrator has had an opportunity to interpret it. The strong federal policy favoring arbitration of labor disputes, as established in the Steelworkers trilogy, requires courts to defer to the grievance and arbitration procedures bargained for by the parties. It is the arbitrator's role, not the court's, to first provide a view on the meaning of the contract. The district court erred by prematurely addressing the legality of Article 19.10, as an arbitrator's interpretation of the contract's terms—such as what constitutes a 'final determination'—could have resolved or avoided the legal question entirely. The proper course was for the district court to stay its own proceedings and allow the parties to proceed to arbitration to interpret the CBA.
Analysis:
This decision strongly reaffirms the principle of judicial deference to arbitration in the context of labor law. It clarifies that this deference extends not only to the merits of a dispute but also to threshold issues of contract interpretation, even when a provision's legality is questioned. The ruling instructs federal courts to act with restraint, prioritizing the contractually agreed-upon dispute resolution mechanism over immediate judicial intervention. This reinforces the role of the arbitrator as the primary interpreter of a collective bargaining agreement and may prevent federal courts from deciding complex statutory or constitutional issues that an arbitrator's interpretation could render moot.
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