## Facts

- Kansas City Royals Baseball Corporation and the other Major League Baseball clubs were parties to a collective bargaining agreement (the 1973 Basic Agreement) with the Major League Baseball Players Association (MLBPA).
- The 1973 Basic Agreement contained a broad grievance-arbitration clause covering disputes involving interpretation of, or compliance with, agreements between the clubs and the MLBPA.
- The agreement also included a provision stating the agreement “does not deal with the reserve system,” along with language limiting bargaining obligations and concerted action concerning the reserve system.
- Players Andy Messersmith and Dave McNally played under standard uniform player contracts that allowed the club to renew the contract unilaterally for one year (the option-year renewal).
- The MLBPA filed grievances asserting that once a player completed the renewed (option-year) season, the club could not continue to reserve the player’s services for the next season.
- A tripartite arbitration panel ruled for the MLBPA, directed that Messersmith and McNally be removed from reserve/disqualified lists, and declared that reserve-list and no-tampering rules did not bar other clubs from negotiating with them.
- The Royals and other clubs sued to set aside the award; the MLBPA counterclaimed under LMRA § 301 to enforce it.
- The district court enforced the award; the clubs appealed.

## Issues

1. Whether the grievances implicating the reserve system were within the scope of the agreement’s arbitration clause despite contract language stating the agreement “does not deal with the reserve system.”
2. Whether the arbitration panel exceeded its authority by issuing an award that did not “draw its essence” from the collective bargaining agreement.

## Decision

- The Eighth Circuit affirmed the judgment enforcing the arbitration award.
- The court held the arbitration panel had jurisdiction because the grievances sought interpretation of contractual provisions within the broad definition of “grievance.”
- The court concluded the “does not deal with the reserve system” provision did not clearly and unmistakably exclude reserve-related interpretive disputes from arbitration.
- The court held the award drew its essence from the collective bargaining agreement because it rested on the panel’s interpretation of the option-year renewal clause and related rules.
- The court approved the district court’s enforcement order, including removing the players from reserve/disqualified lists and directing notice that specified rules did not prevent negotiation with them.

## Legal Principles

- A broad labor-arbitration clause triggers a strong presumption that disputes are arbitrable; exclusion requires clear, forceful evidence of intent to remove the dispute from arbitration.
- Contract language addressing bargaining obligations or economic weapons concerning a subject does not, without clear wording, bar arbitration of interpretive grievances touching that subject.
- Courts must enforce a labor-arbitration award that “draws its essence” from the collective bargaining agreement and may not vacate it merely because the award has significant practical consequences.
- Past practice and the parties’ course of dealing may support an inference that similar disputes were understood to be arbitrable.
- Under LMRA § 301, courts may order compliance with a valid arbitration award as an appropriate remedy.

## Conclusion

The Eighth Circuit enforced the Messersmith/McNally arbitration award, holding that reserve-related grievances framed as contract-interpretation disputes fell within a broad arbitration clause and that the arbitrator’s resolution was judicially enforceable because it drew its essence from the parties’ collective bargaining agreement.


Kansas City Royals Baseball Corp. v. Major League Baseball Players Ass’n, 532 F.2d 615 (8th Cir. 1976)