## Facts

- Eastern Associated Coal Corp. employed James Smith as a truck driver performing safety-sensitive duties on public highways and subject to Department of Transportation (DOT) drug-testing rules.
- Eastern and the Union operated under a collective-bargaining agreement (CBA) requiring “just cause” for discharge and providing that, absent just cause, an arbitrator would order reinstatement; arbitration decisions were final.
- In 1996, Smith tested positive for marijuana; Eastern discharged him and the Union grieved.
- An arbitrator ordered reinstatement with conditions, including an unpaid suspension, substance-abuse treatment, and discretionary drug testing for five years; Smith later passed multiple tests.
- In 1997, Smith again tested positive for marijuana; Eastern discharged him and the Union again sought arbitration.
- The arbitrator again found no just cause to discharge, citing Smith’s long service and a claimed one-time relapse, and ordered reinstatement with stricter conditions: a longer suspension, participation in a treatment program, random testing, payment of arbitration costs, and an undated resignation letter effective upon another positive test within five years.
- Eastern sued to vacate the second award, asserting it violated public policy against allowing drug-using employees to operate dangerous machinery; the district court enforced the award and the Fourth Circuit affirmed.

## Issues

1. Whether a court must refuse to enforce a labor-arbitration award reinstating a safety-sensitive truck driver who twice tested positive for marijuana on the ground that the remedy violates an explicit, well-defined, and dominant public policy reflected in DOT drug-testing regulations.

## Decision

- The Supreme Court affirmed enforcement of the arbitration award.
- The Court held that public policy did not require vacatur because relevant federal regulations did not prohibit conditional reinstatement and did not mandate discharge for a positive test.
- The Court treated the arbitrator’s construction of “just cause” and the remedial choice as controlling absent a direct conflict with positive law.
- A concurrence agreed in the judgment, emphasizing that nonenforcement is proper only when the award requires illegal conduct.

## Legal Principles

- Courts generally enforce labor-arbitration awards that “draw their essence” from a CBA and do not reweigh the merits of discipline or the arbitrator’s chosen remedy.
- The public-policy exception is narrow; the policy must be explicit, well-defined, and dominant, grounded in laws and legal precedents rather than generalized notions of public interest.
- The relevant inquiry is whether the specific contractual term or arbitral remedy violates positive law or directly conflicts with an established legal mandate.
- DOT drug-testing rules impose removal from safety-sensitive functions after a positive test and require evaluation, treatment, and follow-up testing, but they permit return to duty and do not require discharge; an award consistent with that framework is enforceable.

## Conclusion

The Court enforced the arbitrator’s conditional reinstatement of a safety-sensitive truck driver who twice tested positive for marijuana because DOT regulations did not require dismissal and did not forbid reinstatement under strict treatment and monitoring conditions, leaving no direct conflict with an explicit, legally grounded public policy.


E. Associated Coal Corp. v. United Mine Workers of Am., Dist. 17, 531 U.S. 57 (2000)