Question: TEXTILE WORKERS UNION OF AMERICA V. LINCOLN MILLS OF ALABAMA 353 U.S. 448 (1957)

Facts: The Textile Workers Union entered into a collective bargaining agreement with the employer, Lincoln Mills. The agreement provided that there would be no strikes or work stoppages, and contained a grievance procedure. The last step in the grievance procedure was arbitration, which could be invoked by either party. The union processed several grievances concerning work loads and work assignments through the various steps in the grievance procedure, but the employer denied them. The union then requested arbitration, and the employer refused. The union then filed suit under Section 301 of the NLRA to compel the employer to arbitrate the grievances. The trial court ordered the employer to arbitrate the grievances under the arbitration provisions of the collective bargaining agreement. The employer appealed, and the court of appeals reversed the trial court decision. The union then appealed to the U.S. Supreme Court. Issue: Does Section 301 authorize a court to order the parties to a collective agreement to arbitrate a grievance? Decision: The Court looked to the wording of Section 301, which provides:

(a) Suits for violation of contracts between an employer and a labor organization representing employees in an industry affecting commerce as defined in this chapter, or between any such labor organizations, may be brought in any district court of the United States having jurisdiction of the parties, without respect to the amount in controversy or without regard to the citizenship of the parties. Previous decisions involving Section 301 hold that Section 301(a) authorizes federal courts to fashion a body of federal law for the enforcement of collective bargaining agreements, including enforcing of promises to arbitrate grievances under collective bargaining agreements.

The agreement to arbitrate grievance disputes, contained in this collective bargaining agreement, should be enforced. The agreement to arbitrate grievances is the quid pro quo for an agreement not to strike. Section 301 expresses a federal policy that federal courts should enforce these agreements to arbitrate in order to ensure that industrial peace can be promoted. In enforcing agreements to arbitrate under Section 301, the courts should to apply substantive federal law, fashioned from the policy of the national labor laws. The Court also noted that the Norris-La Guardia Act, which restricts federal courts issuing injunctions in labor disputes, does not apply to suits seeking to order arbitration under Section 301. The Supreme Court reversed the decision of the court of appeals and remanded the case.