## Facts

- CCNA/Pennsylvania Association of Staff Nurses and Allied Professionals (PASNAP) represented registered nurses employed by Crozer-Chester Medical Center (CCMC), part of the Crozer-Keystone Health System.
- PASNAP and CCMC were parties to a collective bargaining agreement (CBA) effective June 9, 2014 through June 8, 2019.
- Historically, nurses could carry over unused vacation year to year, creating “banks” of accrued vacation.
- During 2014–2015 bargaining, the parties added a cap on vacation accrual: effective July 1, 2015, employees could not accumulate more than two times (200%) of their annual vacation entitlement.
- In 2016, Prospect acquired Crozer-Keystone’s assets and, through a recognition agreement, assumed the existing CBA and began operating CCMC on July 1, 2016.
- After the acquisition, Prospect applied the 200% cap to reduce vacation balances that had been banked before the cap took effect, reclaiming hours above the cap from employees’ existing banks.
- PASNAP filed a grievance on July 28, 2016 challenging Prospect’s reduction of pre-cap vacation banks.
- The parties stipulated the arbitration question: whether Prospect, as successor, violated the CBA by failing to maintain vacation banks for employees whose accrued balances exceeded the contractual maximum on the acquisition date.
- Arbitrator Kathleen Miller heard the dispute. Prospect sought to present evidence about an NLRB unfair labor practice charge involving a different hospital and bargaining unit; after hearing argument, the arbitrator excluded that evidence.
- The arbitrator issued an award for PASNAP, interpreting the CBA to require maintaining the pre-acquisition vacation banks and directing relief consistent with that interpretation.
- Prospect filed in federal court to vacate the award under § 10(a) of the Federal Arbitration Act (FAA). PASNAP filed a separate action to enforce the award and moved for judgment on the pleadings; the court consolidated the matters.

## Issues

1. Whether Prospect’s motion to vacate the arbitration award under FAA § 10(a) was timely and properly brought under the FAA in this labor-arbitration dispute.
2. Whether the arbitrator exceeded her authority, failed to apply the CBA, or otherwise issued an award that did not draw its essence from the CBA by requiring Prospect to maintain pre-cap vacation banks.
3. Whether the arbitrator’s exclusion of evidence relating to the separate NLRB matter warranted vacatur under FAA § 10(a) as misconduct or a refusal to hear material evidence.

## Decision

- The court held Prospect’s FAA vacatur motion was timely and that proceeding under the FAA was proper.
- The court denied Prospect’s motion to vacate the arbitration award.
- The court granted PASNAP’s motion for judgment on the pleadings in the enforcement action, confirming the arbitration award.
- The court concluded the arbitrator acted within the scope of authority conferred by the parties’ submission and was interpreting and applying the CBA.
- The court found no basis to vacate the award based on the arbitrator’s evidentiary ruling excluding testimony about the separate NLRB dispute.

## Legal Principles

- Judicial review of labor-arbitration awards under a CBA is highly deferential; courts do not correct alleged legal or factual errors if the arbitrator was construing or applying the agreement.
- An award is enforced if it “draws its essence” from the CBA, meaning the arbitrator’s result is rationally derived from the agreement and the submitted issue.
- Vacatur under FAA § 10(a) is limited to narrow grounds (including arbitrator misconduct or exceeding powers) and does not permit relitigation of contract interpretation committed to the arbitrator.
- Arbitrators have broad discretion over evidentiary and procedural rulings; exclusion of evidence supports vacatur only when it results in a fundamentally unfair hearing within the meaning of the FAA.
- When the parties stipulate the question for decision, the arbitrator’s authority is measured by that submission, and a court asks whether the award answers the submitted question by interpreting the CBA.

## Conclusion

The Eastern District of Pennsylvania held that Prospect timely sought vacatur under the FAA but failed to show any ground to set aside the award. Because the arbitrator resolved the stipulated vacation-bank dispute by interpreting the CBA and exercised permissible control over the hearing record, the court denied vacatur and confirmed the award in PASNAP’s favor.


Prospect CCMC, LLC v. CCNA/Pennsylvania Association of Staff Nurses and Allied Professionals, Civ. Action No. 18-174, 2019 U.S. Dist. LEXIS 12714 (2019)