« Ind. Decisions - Court of Appeals issues 0 today (and 2 NFP) | Main | Ind. Decisions - Transfer list for week ending July 3, 2008 »

Thursday, July 03, 2008

Ind. Decisions - 7th Circuit decides one Indiana case today

In United Steel, Paper etc. Union v. TriMas Corp (ND Ind., Judge Springmann), a 14-page opinion, Judge Cudahy writes:

The defendant TriMas Corporation (TriMas) owns a number of heavy manufacturing plants in the Midwest. In July 2003, it signed a neutrality agreement with an organization whose name is a “mouthful”—the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union (Union). In essence, TriMas agreed to cooperate with Union efforts to organize its workforce, at least within certain parameters. The agreement specified that any disputes regarding the terms of the agreement would be settled by arbitration.

In 2005, the Union informed TriMas of its intention to organize the Rieke plant, a TriMas facility in Auburn, Indiana. The Union believes that the Rieke plant is a “covered workplace” subject to the provisions of the agreement requiring neutrality. TriMas, however, refused to accord neutrality to the Union. TriMas claimed that the plain language of the neutrality agreement was not controlling because the neutrality agreement had been modified by an oral side agreement. The modified agreement applied to only three or four plants, it argued, and the Rieke plant was not one of them. When the Union insisted that they submit the dispute to arbitration, TriMas again refused. It characterized the dispute as one involving the “scope” of the agreement itself and so claimed that it had no duty to submit it to arbitration.

The Union then brought this action in federal court to compel arbitration under the Labor-Management Relations Act (LMRA). See 29 U.S.C. § 185(a). The parties filed cross-motions for summary judgement, and the district court granted the Union’s motion. TriMas now appeals, claiming that the district court “ignored” the extrinsic evidence that would have established the existence of the side agreement. We believe that the district court was correct in finding that the dispute was covered by the language of the arbitration clause and in leaving consideration of the extrinsic evidence to the arbitrator.

Posted by Marcia Oddi on July 3, 2008 11:25 AM
Posted to Ind. (7th Cir.) Decisions