Packinghouse Workers v. Needham, 376 U.S. 247 (1964)

Local Union No. 721, United Packinghouse, Food &

Allied Workers, AFL-CIO v. Needham Packing Co.
No. 102

Argued February 20, 1964
Decided March 9, 1964
376 U.S. 247

CERTIORARI TO THE SUPREME COURT OF IOWA

Syllabus

Under § 301(a) of the Labor Management Relations Act, petitioner labor union sued in a state court to compel arbitration of the claimed wrongful discharge of employees, the action being based on a collective bargaining agreement providing for arbitration at the union’s request of disputes which the parties could not settle. Respondent employer contended that the union had struck in violation of a no-strike clause in that agreement, thereby terminating the employer’s obligations thereunder, and it counterclaimed for damages for breach of the no-strike clause. The State Supreme Court affirmed a lower court ruling that the union, by its walkout, had waived its right to arbitrate the grievances.

Held: The union’s alleged breach of its promise in the collective bargaining agreement not to strike did not relieve the employer of its duty under such agreement to arbitrate, there being no inflexible rule that the duty to arbitrate depends upon observance of the promise not to strike. Drake Bakeries, Inc. v. Bakery Workers, 370 U.S. 254, followed. Pp. 248-253.

(a) A state court exercising its concurrent jurisdiction over suits under § 301(a) applies federal substantive law. P. 250.

(b) Though the employer is obliged to arbitrate the union’s grievances, it can pursue its claim for damages in the state court for the alleged breach of the no-strike clause. Pp. 252-253.

(c) The employer is not released from its duty to arbitrate by the passage of time resulting from its refusal to do so. P. 253.

254 Iowa 882, 119 N.W.2d 141, reversed and remanded.