Coastal Oil of New England, Inc. v. Teamsters Local No. 25

Coastal Oil of New England, Inc. (Coastal Oil) (defendant) operated three facilities in Massachusetts, including one in Revere and one in Chelsea. Teamsters Local No. 25 (the union) (plaintiff) represented the employees at each facility in separate bargaining units, each covered by its own collective-bargaining agreement. Joseph Abruzzese, a yardman in Revere, suffered a work-related injury and went on a leave of absence, during which he collected workers’-compensation benefits under state law. Several years later, when Abruzzese could return to work, there were no job openings at Revere. There was, however, an open yardman position at Chelsea. Abruzzese applied for the Chelsea position through the union, but Coastal Oil refused to place Abruzzese there based on the company’s position that Abruzzese could only be reinstated at Revere. The union initiated the grievance procedure, and the matter was submitted to arbitration. The arbitrator reviewed the parties’ labor agreement, which required Coastal Oil to provide workers’-compensation benefits to injured employees in the same manner as provided by state workers’-compensation law. Under the workers’-compensation law, an employer must give a hiring preference to an injured worker who applies for reemployment and provide the worker with a “suitable job.” Based on the arbitrator’s interpretation of the relevant provisions, the arbitrator decided that Abruzzese was entitled to be placed at Chelsea and issued orders to that effect. Coastal Oil appealed to the First Circuit, arguing that the arbitrator did not have authority to interpret the state workers’-compensation law and order a Revere unit member to work in Chelsea.