Columbia Broadcasting System, Inc. v. American Recording & Broadcasting Association

Radio & Television Broadcast Engineers Union, Local 1212, International Brotherhood of Electrical Workers (Local 1212) (defendant), a labor union that initially represented both recording engineers and broadcast technicians, had a collective-bargaining agreement with Colombia Broadcasting System, Inc. (CBS) (plaintiff). The recording engineers left Local 1212 and started a new union, the American Recording and Broadcasting Association (the association) (defendant), after which the association entered into its own collective-bargaining agreement with CBS. CBS’s contracts with Local 1212 and the association had broad arbitration clauses that required all disputes arising under the contracts to be resolved by arbitration. After CBS gave certain work assignments to Local 1212’s broadcast technicians, the association demanded arbitration with CBS, claiming that CBS should have assigned the work to the association’s recording engineers. In turn, CBS demanded arbitration with Local 1212. CBS also filed suit against the association and Local 1212 and motioned the district court to consolidate the two arbitrations into one joint arbitration with the association and Local 1212. Local 1212, although not a party to the contract between CBS and the association, did not object to consolidating the arbitrations and was willing to let the association select the arbitrator. The association opposed the motion to consolidate and moved to dismiss the case on the grounds that the district court lacked jurisdiction to compel joint arbitration.