Granite Rock Co. v. International Brotherhood of Teamsters

The Supreme Court has agreed to decide whether a federal court has jurisdiction to determine collective bargaining agreement formation and whether a §301(a) action is available against a union that is not a direct signatory to the collective bargaining agreement.

The case arose out of negotiations for a new collective bargaining agreement between Teamsters Local 287 and Granite Rock Co. After the negotiations failed and the CBA expired, Local 287 went on strike with the support of the International Brotherhood of Teamsters (IBT). Negotiations resumed during the strike and a tentative agreement was reached for a new four-year CBA, which included an arbitration clause that covered disputes arising under the new CBA and a no-strike clause.

The new CBA was allegedly approved by the union membership but workers went on strike a few days later, in violation of the no-strike clause. Granite Rock filed suit in response to the strike, alleging tortuous interference by IBT and breach of contract by Local 287. The district court, citing the arbitration clause, ordered the case into arbitration but retained the issue of whether the contract was validly formed.

The 9th U.S. Circuit Court of Appeals affirmed, holding that the plain language of the LMRA requires that "the underlying agreement must have created the rights or liabilities which the parties seek to vindicate by their suit."

Question presented: Whether a federal court has jurisdiction to determine collective bargaining agreement formation and whether a §301(a) action is available against a union that is not a direct signatory to the collective bargaining agreement.