Granite Rock Co. v. International Brotherhood of Teamsters

Granite Rock Company (Granite) (plaintiff) employed union members of the International Brotherhood of Teamsters, Local 287 (Local) (defendant). Granite and Local reached an impasse in negotiating a new collective-bargaining agreement (CBA), and Local went on strike for the month of June, supported by its parent international union, International Brotherhood of Teamsters (Brotherhood) (defendant). On July 2, the parties agreed to a new CBA containing a no-strike provision and arbitration clauses covering all disputes arising under the CBA. The CBA stated that it was retroactively effective from May 1. The CBA did not address strike-related damages from the June strike. Brotherhood instructed Local to continue striking until the unions were held harmless for strike damages. The unions renewed striking on July 9. Granite sued the unions in federal court, seeking strike-related damages for the unions’ breach of contract and an injunction against the July strike because the hold-harmless dispute was arbitrable under the CBA. Local ratified the new CBA on August 22, and soon after, the unions ended the strike. The unions disputed whether the CBA was officially ratified in August and whether the no-strike provision could be enforced for July’s strike. Local moved to arbitrate the ratification dispute under the CBA, but the district court denied the motion. The court found that the date dispute should be decided by a jury. The jury found that the CBA was ratified on July 2. The court compelled arbitration of Granite’s breach-of-contract claims under the CBA. The Ninth Circuit reversed the arbitration order, finding that the ratification dispute was a matter for an arbitrator to decide rather than a jury. The United States Supreme Court granted certiorari.