Eastern Associated Coal Corporation v. United Mine Workers of America, District 17

PETITIONER: Eastern Associated Coal Corporation
RESPONDENT: United Mine Workers of America, District 17
LOCATION: Rhode Island General Assembly

DOCKET NO.: 99-1038
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Fourth Circuit

CITATION: 531 US 57 (2000)
ARGUED: Oct 02, 2000
DECIDED: Nov 28, 2000

ADVOCATES:
John R. Mooney - Argued the cause for the respondents
Malcolm L. Stewart - Department of Justice, on behalf of the United States, as amicus curiae, supporting the respondents

Facts of the case

Eastern Associated Coal Corp. and the United Mine Workers of America are parties to a collective-bargaining agreement with arbitration provisions. Under the agreement, in order for Eastern to discharge an employee, it must prove it has "just cause," or the arbitrator will order the employee reinstated. The arbitrator's decision is final. With this framework in place, James Smith worked for Eastern as a truck driver subject to Department of Transportation (DOT) regulations requiring random drug testing of workers engaged in "safety-sensitive" tasks. After Smith tested positive for marijuana use twice, Eastern sought to discharge him. Each time the union went to arbitration. The arbitrator concluded that Smith's positive drug test did not amount to "just cause" for discharge and reinstated him conditionally. After the second occurrence, Eastern filed suit to vacate the arbitrator's award. The District Court ordered the award's enforcement, holding that Smith's conditional reinstatement did not violate the strong regulation-based public policy against drug use by workers who perform safety-sensitive functions. The Court of Appeals affirmed.

Question

Do public policy considerations require federal courts to refuse to enforce arbitrator's awards, which reinstate employees fired for testing positive for marijuana?

Media for Eastern Associated Coal Corporation v. United Mine Workers of America, District 17

Audio Transcription for Oral Argument - October 02, 2000 in Eastern Associated Coal Corporation v. United Mine Workers of America, District 17

Audio Transcription for Opinion Announcement - November 28, 2000 in Eastern Associated Coal Corporation v. United Mine Workers of America, District 17

William H. Rehnquist:

The opinion of the Court in No. 99-1038, Eastern Associated Coal Corporation versus United Mine Workers, will be announced by Justice Breyer.

Stephen G. Breyer:

Eastern Associated Coal Corporation has a collective bargaining agreement with the United Mine workers.

That agreement provides that Eastern must have “just cause” to dismiss a worker.

The agreement also provides for arbitration of disputes about “just what” constitutes “just cause”.

James Smith, a truck driver employed by Eastern twice failed drug testing for marijuana.

Eastern wanted to dismiss him, but each time an arbitrator imposed an alternative punishment upon Smith and then held, in light of that punishment, Eastern did not have “just cause” to dismiss Smith.

Eastern ask the court in effect the set-aside the arbitrator’s second reinstatement.

Eastern claims that on the arbitrator’s interpretation of the words “just cause” the contract is unenforceable, because if the contract requires it to reinstate a worker who failed drug tests twice the contract must violate public policy.

The Fourth Circuit rejected Eastern’s public policy argument.

Other courts in similar circumstances have reached the different conclusion.

We therefore agreed to review the matter.

Now, we agree that with Eastern that in principle a court might sometimes refuse to enforce an agreement on public policy grounds even if enforcement does not violate a positive law such as the statute, but that is as far as our agreement with Eastern guvs.

The public policy exception warranting non-enforcement of a labor arbitration award is narrow.

It is applicable only where the public policy that the contract violates is “explicit”, “well-defined”, “dominant” and “ascertain” by a reference to the laws and legal precedents, not from general considerations of supposed public interests.

Eastern’s drug testing of Smith is subject to a detailed statute and regulations governing the drug testing of transportation workers, that being so that is Congress and the Executive Branch both having spoken, courts must treat with particular caution, any plea to divine some further public policy beyond what the statute and regulations explicitly State.

Eastern is making just such a plea here, the statute and regulations do not explicitly forbid an employer to reinstate a worker who tests positives for drugs once or twice.

Indeed, as we read them they contemplate that reinstatement may take place after the worker has been rehabilitated.

Eastern claims that the arbitrator’s award violates the public policy underlying the statute the policy against drug use by workers in jobs that can propose a risk to others.

But that claim over simplifies the regulatory scheme, the actual statute in the regulations reveal several different relevant policies, including policies against drug use, policies favoring drug testing, policies favoring rehabilitation of those who failed tests and background policies favoring leaving disciplinary matters such as this one to employers and unions to decide to agreed upon arbitration.

We conclude that Smith’s reinstatement with a significant alternative punishment does not run contrary to these statutory and regulation based public policies taken together.

We spell our reasons out further, in our opinion.

We affirm the Fourth Circuit's similar determination.

Justice Scalia has filed an opinion concurring in the judgment which Justice Thomas has joined.