Office of the Commissioner of Baseball v. World Umpires Association
United States District Court for the Southern District of New York
242 F. Supp. 2d 380 (2003)
- Written by Steven Pacht, JD
Facts
The collective-bargaining agreement (CBA) between the Office of the Commissioner of Baseball (commissioner) (plaintiff) and the World Umpires Association (union) (defendant) set forth two dispute-resolution paths. Per Article 23, disputes about the interpretation or application of the CBA or Major League Baseball (MLB) rules or policies could be appealed via an arbitration grievance. Disputes about umpire discipline were governed by Article 10, which provided for review by an MLB official whose decision would be final and binding and not subject to Article 23’s grievance process. Article 10 did not define what constituted discipline, but a warning issued to an umpire was provided as an example. In May 2002, MLB’s Ralph Nelson notified umpire John Hirschbeck that, among other things, his conduct during a recent game violated MLB’s official playing rules and that Hirschbeck’s threat (issued to his supervisor) to violate the rules in the future would have serious repercussions if carried out. The union responded with a letter stating that it was pursuing an Article 23 grievance regarding Nelson’s letter; the union then filed a formal grievance. The commissioner sought both a declaratory judgment that the dispute was not subject to arbitration and a permanent injunction against the arbitration, arguing that the grievance concerned discipline and thus was not subject to Article 23. The union responded that (1) the grievance did not challenge discipline, but rather concerned the commissioner’s interpretation or application of, among other things, the CBA and other MLB rules or policies and (2) disallowing arbitration would give the commissioner unfettered discretion to interpret and apply the CBA and MLB rules and policies. The parties cross-moved for summary judgment.
Rule of Law
Issue
Holding and Reasoning (Kaplan, J.)
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