## Facts

- Storer Broadcasting Company owned Cleveland television station WJKW–TV and employed reporters represented by AFTRA under a collective-bargaining agreement (CBA).
- The CBA’s termination clause (Article 24(b)) allowed discharge for “insubordination, incompetence, misconduct, or any other just and sufficient cause, and unsuitability for staff or program requirements.”
- Reporter James Cox faced termination; the news director told Cox he could resign and still receive severance and termination benefits, but Cox withdrew his resignation offer and was discharged.
- A payroll notice stated the reason for termination as “just and sufficient cause” under the CBA.
- AFTRA grieved the discharge and proceeded to arbitration; Storer presented evidence including alleged harassment of public officials during a news story and additional alleged misconduct such as tardiness and absenteeism.
- The arbitrator sustained the discharge and denied the grievance, stating that while the formal reason was “just and sufficient cause,” “suitability” also played a part in determining termination was appropriate.

## Issues

1. Whether a federal court may remand a labor arbitration award for reconsideration when the court views “just and sufficient cause” and “unsuitability” as separate discharge grounds and believes the arbitrator improperly considered suitability.
2. Whether the arbitrator’s interpretation of an ambiguous CBA discharge clause “draws its essence” from the agreement, requiring judicial enforcement.

## Decision

- The Sixth Circuit reversed the district court’s remand order and reinstated the arbitrator’s award sustaining Cox’s discharge.
- The court held the discharge clause was ambiguous as to how “just and sufficient cause” related to “unsuitability,” and interpreting that ambiguity was the arbitrator’s task.
- Because the arbitrator’s construction was within permissible contract interpretation, the district court improperly substituted its own reading by limiting the arbitrator to “just and sufficient cause” alone.

## Legal Principles

- Judicial review of labor arbitration awards under LMRA § 301 is highly limited; courts may not revisit the merits or impose their preferred contract interpretation.
- An arbitration award must be enforced if it “draws its essence” from the collective-bargaining agreement and is not the arbitrator’s “own brand of industrial justice.”
- When contract language is ambiguous, an arbitrator has authority to resolve the ambiguity, and a court may not vacate or narrow the award merely because it would interpret the language differently.

## Conclusion

The Sixth Circuit held that, given ambiguity in the CBA’s termination clause, the arbitrator could reasonably treat suitability considerations as part of the discharge analysis, and the district court erred by remanding to restrict the arbitrator’s inquiry; the arbitration award upholding the discharge was reinstated.


Am. Fed’n of Television & Radio Artists, Cleveland Local, AFL–CIO v. Storer Broad. Co., 660 F.2d 151 (6th Cir. 1981)