Justia Arbitration & Mediation Opinion SummariesArticles Posted in Aviation
Dodson International Parts v. Williams International Company
Williams International Company LLC designed, manufactured, and serviced small jet engines. Dodson International Parts, Inc., sold new and used aircraft and aircraft parts. After purchasing two used jet engines that had been manufactured by Williams, Dodson contracted with Williams to inspect the engines and prepare an estimate of repair costs, intending to resell the repaired engines. Williams determined that the engines were so badly damaged that they could not be rendered fit for flying, but it refused to return one of the engines because Dodson had not paid its bill in full. Dodson sued Williams in federal court alleging federal antitrust and state-law tort claims. Williams moved to compel arbitration under the Federal Arbitration Act (FAA), relying on an arbitration clause on the original invoices. The district court granted the motion, and the arbitrator resolved all of Dodson’s claims in favor of Williams. Dodson then moved to reconsider the order compelling arbitration and to vacate the arbitrator’s award. The court denied both motions and, construing Williams’s opposition to the motion for vacatur as a request to confirm the award, confirmed the award. Dodson appealed, challenging the district court’s order compelling arbitration and its order confirming the award and denying the motions for reconsideration and vacatur. After review, the Tenth Circuit affirmed, holding: (1) the claims in Dodson’s federal-court complaint were encompassed by the arbitration clause; (2) the district court did not abuse its discretion in denying Dodson’s untimely motion to reconsider; and (3) that Dodson failed to establish any grounds for vacatur of the arbitrator’s award or for denial of confirmation of the award. View "Dodson International Parts v. Williams International Company" on Justia Law
Atlas Air, Inc. v. International Brotherhood of Teamsters
The Second Circuit affirmed the district court's judgment compelling arbitration of grievances raised by airlines in a dispute with the collective bargaining representatives of their pilots.The court held that the district court properly granted the employers' motion for summary judgment and to compel arbitration. The court held that the management grievances did not involve a major dispute; rejected the Union's argument that the case raised issues of representation that would fall within the exclusive jurisdiction of the National Mediation Board; and held that the district court did not err in exercising jurisdiction over the dispute. The court also held that Atlas's motion to compel arbitration of its management grievance was timely.Finally, the court rejected the Union's three arguments with respect to the arbitrability of the employers' management grievances. In this case, Southern was entitled to file a management grievance with the Southern Board regarding the interpretation of Section 1.B.3 of the collective bargaining agreement (CBA); the district court correctly determined that it lacked authority to decide whether the merger provisions of the Atlas CBA were prompted by the announced operational merger of Atlas and Southern; and nothing in the process of interpreting the provisions of the two collective bargaining agreements purports to bind Atlas or Southern pilots to the terms of another existing CBA. View "Atlas Air, Inc. v. International Brotherhood of Teamsters" on Justia Law
Air Line Pilots Association v. Trans States Airlines, LLC
Trans State Airlines, LLC ("TSA") appealed the district court's grant of summary judgment to Air Line Pilots Association International ("ALPA") enforcing an arbitrator's award of backpay to a pilot after TSA fired him. At issue was whether the award violated public policy against large loans to union officials embodied in the Labor Management Reporting and Disclosure Act ("LMRDA"), 29 U.S.C. 401-531. After concluding that TSA had standing to pursue an appeal and that the arbitrator's unreviewed decision in a prior arbitration did not preclude TSA's public policy challenge, the court held that the lack of control, combined with the purpose and structure of the section 60 payments in ALPA's Administrative Manual, weighed against finding the payments were an illegal loan.