## Facts

- A union and an employer were parties to a collective bargaining agreement (CBA) requiring arbitration of disputes about the agreement’s “meaning and application.”
- The CBA provided that employees discharged in violation of the agreement must be reinstated with back pay.
- During the CBA’s term, the employer discharged certain employees.
- After the CBA expired, the dispute proceeded to arbitration.
- The arbitrator found the discharges violated the CBA and ordered reinstatement and back pay, with deductions for a 10-day suspension and interim earnings.
- The employer refused to comply, and the union sought judicial enforcement.
- The district court ordered full compliance with the award.
- The court of appeals limited enforcement, reasoning that (a) the award was unenforceable without specifying exact deduction amounts, (b) post-expiration back pay was unenforceable, and (c) reinstatement was unenforceable because the CBA had expired.

## Issues

1. Whether a court may refuse to enforce a labor arbitration award because the arbitrator’s opinion is ambiguous or may imply an overreach of authority.
2. Whether an arbitrator may award reinstatement and back pay extending beyond CBA expiration when the wrongful discharge occurred during the CBA term.
3. Whether failure to state precise monetary amounts makes an award unenforceable, or instead permits a limited return to arbitration to compute sums due.

## Decision

- The Supreme Court reversed the court of appeals and remanded.
- The Court held the district court’s enforcement order should be affirmed with a limited modification requiring arbitration to determine the specific amounts due.
- The Court rejected the court of appeals’ refusal to enforce reinstatement and post-expiration back pay.
- The Court stated that federal courts should decline to review the merits of arbitration awards under CBAs and should not replace the arbitrator’s contract interpretation with their own.

## Legal Principles

- Courts generally may not review the merits of a labor arbitration award; contract interpretation committed to arbitration is for the arbitrator, not the court.
- An arbitration award is enforceable if it is grounded in the CBA; courts may not overturn it merely because they read the contract differently.
- Ambiguity in the arbitrator’s accompanying opinion is not, by itself, a basis to refuse enforcement, even if it permits an inference the arbitrator may have exceeded contractual authority.
- Expiration of a CBA does not automatically bar enforcement of reinstatement or back pay remedies for discharges that occurred during the CBA term, even if the remedial period extends beyond expiration.
- When an award establishes entitlement but does not calculate exact back-pay amounts, the proper judicial action is to enforce the award and, if needed, require a limited return to arbitration to determine the specific sums.

## Conclusion

The Court enforced the labor arbitration award ordering reinstatement and back pay for discharges that violated the CBA, holding that courts must not revisit the merits or the arbitrator’s contract interpretation, that ambiguity in the arbitrator’s opinion does not defeat enforcement, and that remedies may extend beyond the CBA’s expiration, with any necessary monetary calculations completed through further arbitration.


United Steelworkers of Am. v. Enter. Wheel & Car Corp., 363 U.S. 593 (1960)