## Facts

- A collective bargaining agreement between a steelworkers’ union and an employer established a grievance procedure and arbitration for disputes over the “meaning, interpretation and application” of the agreement.
- An employee (Sparks) suffered a work-related injury and later settled a workers’ compensation claim on the basis of a 25% permanent partial disability.
- The union filed a grievance asserting that Sparks was entitled to return to work under the agreement’s seniority provisions, which required employment and promotion based on seniority where ability and efficiency were equal.
- The agreement included a no-strike clause tied to compliance with arbitration decisions and reserved to management authority to suspend or discharge employees for cause.
- The union sued under § 301(a) of the Labor Management Relations Act to compel arbitration; the employer argued estoppel from the compensation settlement, physical inability to work, and nonarbitrability.

## Issues

1. In a § 301(a) action to compel arbitration under a broadly worded labor arbitration clause, may a court refuse to order arbitration by evaluating the grievance as “frivolous” or “patently baseless”?
2. Is the court’s role limited to determining whether the grievance, on its face, falls within the scope of the arbitration clause?

## Decision

- The Supreme Court reversed the judgment that denied arbitration.
- The Court held that the judicial function is confined to deciding whether the party seeking arbitration asserts a claim that, on its face, is governed by the collective bargaining agreement.
- Courts may not weigh the merits of the grievance, assess its equity, or decide whether the contract language ultimately supports the claim.
- Because the grievance sought reinstatement based on contractual seniority and related provisions, it was subject to arbitration; defenses such as estoppel and physical ability were for the arbitrator.

## Legal Principles

- Federal labor policy favors final adjustment of grievance disputes by the dispute-resolution method chosen by the parties in their collective bargaining agreement.
- When an agreement commits disputes over contract interpretation or application to arbitration, courts must separate arbitrability (for the court) from the merits (for the arbitrator).
- A court may not deny arbitration on the ground that a grievance appears weak, meritless, or likely to fail; the parties’ agreement is to arbitrate covered grievances, not only those a court deems meritorious.
- Defenses bearing on entitlement to relief under the contract (including estoppel and employability) are generally merits questions reserved to arbitration when the grievance is facially within the arbitration clause.

## Conclusion

The Court required arbitration because the grievance facially concerned the application of the collective bargaining agreement, and it ruled that courts exceed their limited § 301 role when they refuse arbitration by judging the grievance’s merits.


United Steelworkers of Am. v. Am. Mfg. Co., 363 U.S. 564 (1960)