## Facts

- The Major League Baseball Players Association (MLBPA) and Major League Baseball Clubs resolved collusion grievances from the mid-1980s through a global settlement creating a $280 million fund for injured players.
- The MLBPA adopted a detailed distribution “Framework” to evaluate individual claims, allowing arbitral review only of whether the Framework and its criteria were properly applied in the proposed distribution plan.
- Under the Framework, a lost contract-extension claim required evidence that a club made a specific extension offer before collusion that was later withdrawn when collusion began.
- Steve Garvey sought roughly $3 million, alleging the San Diego Padres did not extend his contract for 1988–1989 due to collusion.
- The MLBPA denied the claim for lack of evidence of a specific extension offer; Garvey proceeded to arbitration and submitted a letter from Padres executive Ballard Smith asserting an extension offer had been made and later abandoned due to collusion.
- The arbitrator rejected the claim, finding no qualifying extension offer and treating Smith’s letter as not credible because it conflicted with Smith’s earlier sworn testimony in prior collusion proceedings.

## Issues

1. Whether a federal court reviewing a labor-arbitration award under § 301 of the LMRA may reject the arbitrator’s factual findings and effectively decide the merits by reweighing evidence and credibility.
2. Whether a court of appeals may direct entry of an arbitral award for a party, rather than remanding for further arbitration, after concluding the original award should not stand.

## Decision

- The Supreme Court reversed the Ninth Circuit in a per curiam decision.
- The Court held that judicial review of labor-arbitration awards is extremely limited and does not permit merits review based on alleged factual errors or mistaken contract interpretation.
- The Ninth Circuit improperly reweighed evidence and credibility regarding Smith’s letter and substituted its judgment for the arbitrator’s.
- The Court reinstated the arbitrator’s award denying Garvey’s claim, leaving in place the district court’s confirmation of that award.

## Legal Principles

- Judicial review of labor-arbitration decisions under a collective-bargaining agreement is very limited.
- Courts may not review the arbitrator’s decision on the merits, even when the challenger alleges serious factual error or misinterpretation of the agreement, so long as the arbitrator is arguably construing and applying the contract within delegated authority.
- Credibility determinations and evidentiary weight are core arbitral functions; courts may not second-guess them in § 301 review.
- An arbitration award is unenforceable only if the arbitrator exceeds authority by dispensing “his own brand of industrial justice,” rather than applying the parties’ agreement.
- When a court vacates a labor-arbitration award, the ordinary remedy is remand for further arbitration, not judicial selection of the outcome.

## Conclusion

The Supreme Court held that the Ninth Circuit exceeded the proper scope of § 301 review by reexamining evidence and directing a merits result, and it restored the arbitrator’s denial of Garvey’s settlement claim under the parties’ agreed distribution Framework.


Major League Baseball Players Ass’n v. Garvey, 532 U.S. 504 (2001)