TIMOTHY J. CORRIGAN, District Judge.
Plaintiff brought this case under the Federal Arbitration Act ("FAA") and 29 U.S.C. §185, also known as Section 301 of the Labor Management Relations Act ("LMRA"), asking for vacatur of an arbitration award issued in a dispute over a collective bargaining agreement.
Under §301 of the LMRA, a motion to vacate an arbitration award should only be granted if the award is irrational, exceeds the scope of the arbitrator's authority, or fails to draw its essence from the collective bargaining agreement.
Here, Plaintiff, JAX Transit Management ("JTM"), is the employer of record for bus operators and maintenance employees providing services to the Jacksonville Transportation Authority. (Doc. 1 at 1). Its employees are represented by the Defendant, Amalgamated Transit Union Local Division No. 1197 ("the Union"). (Doc. 1 at 1). The parties sought arbitration over whether JTM breached the collective bargaining agreement with the Union when JTM did not contribute to the group insurance program in December 2011. (Doc. 1 at 3). The underlying dispute revolved around Article 28 of the collective bargaining agreement, which listed JTM's "maximum contribution per eligible operator for the group insurance program". (Doc. 1 - Ex. A at 28). These contributions were expressly limited to use for payment of insurance premiums. (Doc.1 - Ex. A at 29).
Under a new health care plan, the Union did not owe any premium payments for healthcare coverage for December 2011. (Doc. 1 at 3). JTM therefore refused to pay any contribution for December 2011, arguing that, in the absence of any premiums, there was no way to make a contribution limited to the payment of insurance premiums. (Doc. 1 - Ex. C at 8). The dispute then went to arbitration. Under the terms of the collective bargaining agreement, the "scope of the Arbitrator's authority (was) limited to conducting the hearing, examining the witnesses of each party, considering the evidence and briefs, if any, and interpreting the language of the Agreement for the sole purpose of determining whether a specified provision thereof (was) breached . . . ." (Doc. 1 - Ex. A at 9). The arbitrator found no explicit language addressing a procedure for handling a month with no premiums. (Doc. 1 - Ex. C at 8). However, in interpreting the agreement, the arbitrator found that the collective bargaining agreement required JTM to use the maximum December 2011 contribution to defray the employees' portion of the premium in future months. (Doc. 1 - Ex. C at 10). The money from the December 2011 contribution was to be used to pay for the employees' share of the premiums for as long as the funds lasted. (Doc. 1 - Ex. C at 8).
For this arbitration award to be vacated, the award must have been either an action in excess of the arbitrator's authority, not derived from the essence of the collective bargaining agreement, or irrational.
First, the arbitrator did not exceed the scope of his authority. The arbitrator ruled that JTM violated a specific provision, Article 28, of the agreement. (Doc. 1 - Ex. C at 10). In doing so, the arbitrator fulfilled exactly the scope of his authority under the agreement, which allowed him to interpret the agreement's language to determine if a specific provision was breached. (Doc. 1 - Ex. A at 9).
Second, the award was drawn from the essence of the agreement. An award fails to draw its essence from an agreement when it contradicts the express terms of the agreement.
Finally, the award was not irrational. It is not for this court to determine whether the arbitrator's ruling was correct, but only whether it was arguably an application of the contract.
Defendant requested confirmation of the arbitration award under Section 9 of the FAA. (Doc. 15 at 11). As discussed previously, the FAA is inapplicable to suits arising out of arbitration under a collective bargaining agreement.
Accordingly, it is hereby
1. Plaintiff's Motion to Vacate Arbitration Award (Doc. 1) is
2. Defendant's Request for Confirmation of the Arbitration Award (Doc. 15) is
3. The Clerk shall close the file.