United Parcel Svc., Inc. v. Mitchell
Annotate this Case
451 U.S. 56 (1981)
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U.S. Supreme Court
United Parcel Svc., Inc. v. Mitchell, 451 U.S. 56 (1981)
United Parcel Service, Inc. v. Mitchell
Argued February 24, 1981
Decided April 20, 1981
451 U.S. 56
After respondent employee had been discharged by petitioner employer for alleged dishonest acts, respondent requested his union to file a grievance contesting the discharge. The collective bargaining agreement provided a grievance and arbitration procedure for the resolution of covered disputes. Respondent was represented by the union at an arbitration hearing which resulted in a decision upholding the discharge. Seventeen months later, respondent filed suit in Federal District Court against the union and petitioner under § 301(a) of the Labor Management Relations Act, alleging that the union had breached its duty of fair representation and that petitioner discharged him not for the stated reasons, which it knew to be false, but to replace full-time employees with part-time employees. The court. granted summary judgment for the defendants on the ground that the action was barred by New York's 90-day statute of limitations for actions to vacate arbitration awards. The Court of Appeals reversed, holding that the District Court should have applied New York's 6-year limitations period for breach of contract actions.
Held: Given the choices present here, and the undesirability of the results of the grievance and arbitral process being suspended in limbo for long periods, the District Court properly chose the 90-day period for the bringing of an action to vacate an arbitration award. Cf. Hines v. Anchor Motor Freight, Inc., 424 U. S. 554. Pp. 451 U. S. 60-64.
(a) The timeliness of a § 301 suit is to be determined, as a matter of federal law, by reference to the appropriate state statute of limitations, and the determination of which limitations period is the most appropriate depends upon the nature of the federal claim and the federal policies involved. Auto Workers v. Hoosier Cardinal Corp., 383 U. S. 696. Pp. 451 U. S. 60-61.
(b) Although not styled as one to vacate the arbitration award, respondent's suit, if successful, would have that direct effect. He raised the same claim that was raised before the arbitrators -- that he was discharged in violation of the collective bargaining agreement. He sought the same relief -- reinstatement with full backpay. While his underlying claim against his employer was based on the collective
bargaining agreement, the indispensable predicate for the § 301(a) action was not a showing under traditional contract law that the discharge was a breach of the agreement, but instead that the union breached its duty of fair representation. Since the arbitrators' conclusion was, under the collective bargaining agreement, "binding on all parties," respondent was required to show that the union's duty to represent him fairly at the arbitration had been breached before he was entitled to reach the merits of his contract claim. Thus, the suit is more analogous to an action to vacate an arbitration award than to a straight contract action. Pp. 451 U. S. 61-62.
(c) An employee's unfair representation claim against his union, even though his employer may ultimately be called upon to respond in damages if he is successful, is more a creature of "labor law" as it has developed since the enactment of § 301 than it is of general contract law. And one of the leading federal policies in this area is the relatively rapid disposition of labor disputes. The system of industrial self-government, with its heavy emphasis on grievance, arbitration, and the "law of the shop," could easily become unworkable if a decision which has given "meaning and content" to the terms of an agreement, and even affected subsequent modifications of the agreement, could suddenly be called into question as much as six years later. Pp. 451 U. S. 63-64.
624 F.2d 394, reversed.
REHNQUIST, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, WHITE, MARSHALL, BLACKMUN, and POWELL, JJ., joined. BLACKMUN, J., filed a concurring opinion, post, p. 451 U. S. 64. STEWART, J., filed an opinion concurring in the judgment, post, p. 451 U. S. 65. STEVENS, J., filed an opinion concurring in part and dissenting in part, post, p. 451 U. S. 71.