Eastern Associated Coal Corp. v. Mine Workers

Eastern Associated Coal Corp. v. Mine Workers: Background

The case of Eastern Associated Coal Corp. v. Mine Workers is a landmark matter heard before the United Supreme Court.

The United Mine Workers of America and the Eastern Associated Coal Corporation were the main players in the case. These two entities were parties to a collective-bargaining deal that carried several arbitration provisions. Under the agreement, the Eastern Associated Coal Corporation, to discharge employees, was required to prove “just cause.” If this was not proven, the arbitrator to the agreement would be required to reinstate the respective employee. The decision rendered by the arbitrator was deemed final under the agreement.

With this agreement in place all workers were subject to the Department of Transportation’s regulations. After, James Smith, a truck driver for the Eastern Associated Coal Corporation, tested positive for marijuana, the Eastern Company sought to terminate his employment. Each time the Eastern attempted to discharge him, the union went to an arbitrator. The arbitrator concluded that Smith’s drug test did not amount to “just cause” for discharge. Upon this ruling, the arbitrator reinstated Mr. Smith conditionally.

In response to his reinstatement, the Eastern Associated Coal Corporation filed suit to vacate the arbitrator’s decision. The District Court ordered for the enforcement, holding that Smith’s reinstatement did not violate the regulation-based policy against drug use by employees who perform safety-sensitive functions. The Court of Appeals affirmed this decision. The case eventually made its way to the United States Supreme Court as the Eastern Associated Coal Corp. v. Mine Workers case.

Eastern Associated Coal Corp. v. Mine Workers: The Question

The question of Eastern Associated Coal Corp. v. Mine Workers revolved around whether public policy considerations require the federal court system to refuse to enforce an arbitrator’s awards, which unequivocally reinstate employees who are fired for positive drug tests.

Eastern Associated Coal Corp. v. Mine Workers: The Decision

In a unanimous 9-0 vote, the United States Supreme Court in Eastern Associated Coal Corp. v. Mine Workers sided with the workers. In an opinion offered by Stephen Breyer, the United States Supreme Court in Eastern Associated Coal Corp. v. Mine Workers held that under the bargaining agreement formulated by Eastern and the United Mine Workers of America, the arbitration award, was not contrary to well defined public policy. The court in Eastern Associated Coal Corp. v. Mine Workers stated that public policy exception to enforcing the award is narrow and as a result must be dominant and explicit. Moreover, this exception must be ascertained by reference to law and not from considerations of expected public interests.