## Facts

- Adrian Peterson pleaded nolo contendere in Texas state court to misdemeanor reckless assault involving one of his children.
- The NFL’s Personal Conduct Policy and the parties’ collective bargaining agreement (CBA) authorize discipline for “conduct detrimental” to the league.
- Before Peterson’s plea, the Commissioner announced an “enhanced” domestic-violence disciplinary approach, generally calling for a six-game suspension for a first offense.
- The Commissioner suspended Peterson indefinitely and imposed a fine equal to six games’ pay.
- The NFLPA filed a grievance under the CBA; the Commissioner designated Harold Henderson as arbitrator.
- The NFLPA argued the enhanced discipline could not be applied to pre-announcement conduct and that prior disciplinary outcomes constrained punishment.
- The arbitrator upheld the discipline, concluding the Commissioner had broad discretion under the CBA and could consider the enhanced standards.
- The district court vacated the award, finding the arbitrator exceeded authority by allowing retroactive application of a new policy.
- On appeal, Peterson had been reinstated; the dispute centered on whether the NFL could collect the fine.

## Issues

1. Whether the district court erred in vacating the arbitration award on the ground that the arbitrator exceeded his authority under the CBA.
2. Whether the arbitrator’s acceptance of the Commissioner’s enhanced domestic-violence discipline and rejection of “law of the shop” limits were impermissible retroactive policymaking rather than contract interpretation.

## Decision

- The Eighth Circuit reversed the district court and reinstated the arbitration award.
- The court held judicial review of labor-arbitration awards is extremely limited; the question is whether the arbitrator was arguably interpreting and applying the CBA within the scope of authority the parties granted.
- Because the arbitrator grounded his decision in the CBA’s “conduct detrimental” provisions and the Commissioner’s disciplinary authority, the award drew its essence from the agreement and had to be enforced.
- Disputes framed as retroactivity and consistency with past discipline were treated as interpretive questions committed to the arbitrator, not bases for vacatur.

## Legal Principles

- A labor-arbitration award must be enforced if it “draws its essence” from the CBA and the arbitrator is even arguably construing or applying the contract within delegated authority.
- Courts may not vacate an award simply because they disagree with the arbitrator’s interpretation or would interpret the CBA differently.
- Whether a disciplinary standard is “new,” “retroactive,” or inconsistent with prior practice is typically a matter of CBA interpretation for the arbitrator when the agreement confers broad disciplinary discretion.
- “Law of the shop” arguments based on past outcomes do not justify vacatur where the arbitrator considered them and reasonably determined the CBA does not make past discipline binding.

## Conclusion

The Eighth Circuit reinstated the arbitrator’s decision upholding the Commissioner’s discipline, emphasizing that courts must defer to labor-arbitration awards when the arbitrator’s reasoning is plausibly rooted in the CBA and within the authority the parties agreed to submit to arbitration.


Nat'l Football League Players Ass'n v. Nat'l Football League, 831 F.3d 985 (8th Cir. 2016)