MLB PLAYERS ASSN v. GARVEY
After the Major League Baseball Players Association filed grievances against the Major League Baseball Clubs, arbitrators found that the Clubs had colluded in the market for free-agent services in violation of the industry's collective bargaining agreement. To cover damages, the Association and Clubs entered into an agreement, which provided funds and framework to resolve individual player's claims. Steve Garvey, a first baseman, submitted a claim alleging that the San Diego Padres did not extend his contract to the 1988 and 1989 seasons due to collusion. Under the framework, the Association denied Garvey's claim. Agreeing, the arbitrator determined that Garvey did not receive a contract extension due to collusion and found that Garvey had not shown a specific offer of extension. Ultimately, the Court of Appeals reversed the District Court's denial of Garvey's motion to vacate the arbitrator's award. The appellate court, under the Labor Management Relations Act, directed the arbitration panel to enter an award for Garvey because it concluded from the arbitration proceedings that an offer was made to Garvey and that it was withdrawn due to collision.
Did the Court of Appeals err in reversing the District Court's denial of a baseball player's motion to vacate an arbitration award and in directing the arbitrator to enter judgment in favor of the player, where the arbitrator denied the player's claim?
Yes. In a per curiam opinion, the Court reversed the Court of Appeals' determination because it conflicted with the Court's cases limiting review of an arbitrator's award entered pursuant to an agreement between an employer and a labor organization and prescribing the appropriate remedy where vacation of the award is warranted. The opinion stated that: "Judicial review of a labor- arbitration decision pursuant to such an agreement is very limited. Courts are not authorized to review the arbitrator's decision on the merits despite allegations that the decision rests on factual errors or misinterprets the parties' agreement." The opinion continued "even 'serious error' on the arbitrator's part does not justify overturning his decision, where, as here, he is construing a contract and acting within the scope of his authority."