## Facts

- Coastal Oil operated multiple Massachusetts facilities, including Revere and Chelsea, with separate bargaining units and separate collective bargaining agreements (CBAs), all represented by the same union.
- Joseph Abruzzese, a Revere-unit yardman, suffered a work-related injury in 1991 and took leave while receiving benefits under Massachusetts workers’ compensation law.
- By August 1995, Abruzzese was able to return to work, but no Revere-unit openings existed; Coastal Oil and the union agreed he would be reinstated to the next available position.
- A yardman position later opened at the Chelsea facility; Abruzzese sought the job through the union, but Coastal Oil refused, asserting his reinstatement rights were limited to the Revere unit.
- The union filed a grievance under the Revere CBA, and the dispute went to arbitration.
- The arbitrator construed the Revere CBA’s requirement that workers’ compensation benefits be provided “in the same manner” as Massachusetts law as incorporating statutory reemployment preferences for injured employees.
- The arbitrator ordered Coastal Oil to place Abruzzese into the open Chelsea yardman position and to provide related relief.

## Issues

1. Whether the arbitrator exceeded his authority by interpreting Massachusetts workers’ compensation law referenced in the Revere CBA.
2. Whether the arbitrator exceeded his authority by ordering a remedy placing a Revere-unit employee into a position at the Chelsea facility, a different bargaining unit with a separate CBA.
3. Whether the award drew its essence from the Revere CBA and the parties’ submission, rather than the arbitrator’s independent notions of fairness.

## Decision

- The First Circuit affirmed the judgment enforcing the arbitration award.
- The court held the arbitrator acted within his authority when interpreting state workers’ compensation obligations as incorporated by the Revere CBA.
- The court held the arbitrator’s remedial order placing Abruzzese into the Chelsea opening was within the arbitrator’s broad remedial discretion and within the scope of the dispute the parties submitted.
- The court rejected vacatur based on the award’s practical effects on another bargaining unit, absent a clear contractual limitation or a remedy untethered to the Revere CBA.

## Legal Principles

- Judicial review of labor-arbitration awards is highly deferential; an award must be enforced if the arbitrator is even arguably construing or applying the CBA and acting within the parties’ submission.
- When a CBA incorporates state law by reference, an arbitrator’s interpretation of the incorporated law is treated as contract interpretation for purposes of judicial review.
- Arbitrators have broad discretion to fashion remedies that implement contractual rights; a remedy is upheld if rationally related to the CBA and the dispute submitted, even if it has effects beyond the immediate worksite or unit.

## Conclusion

The court enforced the arbitration award because the arbitrator plausibly construed the Revere CBA’s incorporation of Massachusetts workers’ compensation requirements and selected a contract-based remedy—placement into the available Chelsea yardman position—within the scope of the parties’ submitted dispute and the arbitrator’s remedial authority.


Coastal Oil of New England, Inc. v. Teamsters Local Union No. 25, 134 F.3d 466 (1st Cir. 1998)