United Paperworkers International Union, AFL-CIO v. Misco, Inc.

484 U.S. 29, 108 S. Ct. 364 (1987)

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United Paperworkers International Union, AFL-CIO v. Misco, Inc.

United States Supreme Court
484 U.S. 29, 108 S. Ct. 364 (1987)

Facts

Misco, Inc. (plaintiff) entered into a collective-bargaining agreement (CBA) with the United Paperworkers International Union, AFL-CIO, and its local union (union) (defendant). The CBA covered the production and maintenance employees at Misco’s paper-converting plant. The agreement included a provision allowing both parties to submit issues to binding arbitration if the issues involved the application or interpretation of the terms included in the CBA. The CBA allowed Misco to create or enforce employee-discipline rules. Misco listed having or consuming controlled substances at the plant or reporting for work under the influence as grounds for discharge. Isaiah Cooper worked the night shift at the plant as a union employee under the CBA and operated a paper-cutting machine that was hazardous and had caused injuries. Police found Cooper and other men from the plant in the back seat of a smoke-filled car; a lit marijuana cigarette was in the front ashtray. Police also searched Cooper’s nearby car and found marijuana remnants. Cooper was arrested for possession and was discharged from his job by Misco. At the time of discharge, Misco did not know about the marijuana found inside of Cooper’s car, only that Cooper was found at the plant in a smoky car with a lit marijuana cigarette in the front seat. Cooper submitted a grievance, and the matter went to arbitration. Misco learned about the marijuana in Cooper’s car prior to the hearing; however, the arbitrator refused to accept that fact into evidence because Misco did not know about the drugs in Cooper’s car at the time of discharge. The arbitrator ruled in favor of Cooper’s reinstatement because the lit cigarette in the front seat of the smoky car did not prove that Cooper possessed or consumed marijuana at the plant. Misco filed suit in federal district court to vacate the award, claiming that the reinstatement violated public-safety policy. The district court and the appellate court both found that, considering the full evidence, reinstatement violated the public policy against operating dangerous machinery by people under the influence. The union appealed to the United States Supreme Court, arguing that a court could not set aside an arbitration award based on general public policy.

Rule of Law

Issue

Holding and Reasoning (White, J.)

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