## Facts

- Screen Actors Guild (SAG) was a labor union representing roughly 165,000 media artists, including performers used in motion pictures.
- Goldade Productions Inc. was a production company that wanted to produce a film using SAG members.
- SAG and Goldade entered into written agreements allowing Goldade to use SAG performers on condition that the film would receive only a limited release in specified markets.
- The parties’ paperwork also tied Goldade to the terms of SAG’s collective-bargaining agreement (CBA), including the CBA’s grievance and arbitration procedure.
- Goldade later released the film in additional markets beyond the limited-release terms.
- SAG submitted the dispute to arbitration under the CBA procedure and sought monetary relief based on Goldade’s expanded distribution.
- Goldade declined to participate in the arbitration, either in person or electronically.
- The arbitrator issued an award of damages in SAG’s favor.
- Goldade did not pay the award.
- SAG filed suit in federal court seeking confirmation of the arbitration award and requested additional amounts for late payment plus attorney’s fees and costs.

## Issues

1. Did Goldade agree to arbitrate this dispute under the parties’ documents and SAG’s CBA, making the arbitrator’s award subject to confirmation under LMRA § 301?
2. Under the deferential standard of review for labor-arbitration awards, should the court confirm the award?
3. Could the court add late-payment charges and attorney’s fees beyond what the arbitrator awarded?

## Decision

- The court confirmed the arbitrator’s damages award in SAG’s favor.
- The court rejected SAG’s request to add additional late-payment amounts beyond the arbitrator’s award.
- The court denied SAG’s request for attorney’s fees, and awarded only allowable costs.

## Legal Principles

- A federal court asked to enforce a labor-arbitration award under LMRA § 301 first determines whether the parties formed an agreement requiring arbitration and whether the dispute falls within the scope of that agreement.
- Review of a labor-arbitration award is highly limited; courts do not reconsider the merits and will enforce an award that draws its basis from the parties’ labor contract.
- A court confirming an arbitration award generally does not increase the monetary remedy; added damages must rest on a contract term, statute, or other recognized basis authorizing supplementation of the award.
- Under the American Rule, attorney’s fees are not recoverable absent an enforceable contractual fee term, a statute allowing fees, or a recognized exception (such as bad-faith litigation conduct).

## Conclusion

In *Screen Actors Guild v. Goldade Productions Inc.*, the federal district court enforced the labor-arbitration process by confirming SAG’s arbitral damages award against a producer that exceeded a limited-release arrangement, but declined to increase the recovery by adding extra late-payment amounts or shifting SAG’s attorney’s fees.


Screen Actors Guild v. Goldade Productions Inc., 2014 WL 3557320 (2014)