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National Football League Players Ass'n v. National Football League

Court of Appeals for the Eighth Circuit
831 F3d 985, 206 L.R.R.M. (BNA) 3728, 2016 U.S. App. LEXIS 14237 (2016)
ELI5:

Sections

Rule of Law:

Federal courts must enforce a labor arbitration award so long as the arbitrator is arguably construing or applying the collective bargaining agreement and acting within the scope of their authority, even if the court is convinced the arbitrator committed a serious error.


Facts:

  • In May 2014, Minnesota Vikings player Adrian Peterson hit his four-year-old son with a tree branch as a form of corporal punishment, causing cuts and bruises to the child.
  • In August 2014, NFL Commissioner Roger Goodell issued a memorandum to all NFL personnel announcing that domestic violence violations would be subject to a baseline suspension of six games.
  • In September 2014, a grand jury indicted Peterson for injury to a child, and in November 2014, Peterson pleaded nolo contendere to a reduced charge of misdemeanor reckless assault.
  • Following the plea, Commissioner Goodell suspended Peterson indefinitely for a minimum of six games and fined him six weeks' pay, citing the baseline discipline announced in the August 2014 memorandum and the specific severity of the incident.

Procedural Posture:

  • The NFL Players Association appealed the Commissioner's discipline to an arbitrator designated under the Collective Bargaining Agreement.
  • The arbitrator denied the grievance and affirmed the suspension and fine.
  • The NFL Players Association petitioned the United States District Court for the District of Minnesota to vacate the arbitration award.
  • The District Court granted the petition, ruling that the arbitrator ignored the 'law of the shop' regarding retroactivity and exceeded his authority.
  • The National Football League appealed the District Court's judgment to the United States Court of Appeals for the Eighth Circuit.

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Issue:

Is the arbitration award upholding the player's suspension valid under the Labor Management Relations Act, given the arbitrator's determination that the Commissioner had authority to apply increased discipline levels announced after the player's misconduct?


Opinions:

Majority - Colloton

Yes, the arbitration award is valid because the arbitrator acted within his authority to interpret the Collective Bargaining Agreement (CBA). The court emphasized that judicial review of labor arbitration is extremely limited; courts cannot overrule an arbitrator simply because they disagree with his interpretation of the contract or the 'law of the shop.' In this instance, the arbitrator explicitly considered the relevant precedents (such as the Rice and Dolphins Player decisions) and the text of the CBA. The arbitrator concluded that the Commissioner's August 2014 memorandum was not a 'new policy' barring retroactive application, but rather a reinforcement of the Commissioner's existing broad discretion to impose discipline. Because the arbitrator was 'arguably construing' the contract and precedents to reach this conclusion, the federal courts have no authority to vacate the award. Additionally, the court rejected arguments regarding the arbitrator's partiality and 'fundamental fairness,' noting that the parties bargained for an arbitration process where the Commissioner could appoint the arbitrator.



Analysis:

This decision reinforces the extremely high bar required to vacate a labor arbitration award in federal court. By reversing the district court, the Eighth Circuit signaled that even if an arbitrator's legal reasoning appears flawed or questionable (such as applying a 'new' disciplinary standard to past conduct), the award will stand as long as it draws its essence from the collective bargaining agreement. It validates the broad disciplinary powers of the NFL Commissioner under the CBA and confirms that unions are bound by the dispute resolution mechanisms they negotiate, including the specific arbitrators appointed under those agreements.

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