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Eastern Associated Coal Corp. v. Mine Workers
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NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.
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SUPREME COURT OF THE UNITED STATES
Syllabus
EASTERN ASSOCIATED COAL CORP. v. UNITED
MINE WORKERS OF AMERICA, DISTRICT 17, ET AL.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR
THE FOURTH CIRCUIT
No. 99–1038. Argued October 2, 2000—Decided November 28, 2000
The arbitration provisions in petitioner Eastern Associated Coal Corp.’ s
collective-bargaining agreement with respondent union specify, inter
alia, that Eastern must prove in binding arbitration that it has “just
cause” to discharge an employee, or else the arbitrator will order the
employee reinstated. James Smith worked for Eastern as a truck
driver subject to Department of Transportation (DOT) regulations
requiring random drug testing of workers engaged in “safety-sensitive”
tasks. After each of two occasions on which Smith tested
positive for marijuana, Eastern sought to discharge him. Each time,
the union went to arbitration, and the arbitrator concluded that the
drug use did not amount to “just cause” and ordered Smith’ reinstatement
on certain conditions. On the second occasion, Eastern
filed suit to vacate the arbitrator’ s award. The District Court ordered
the award’ s enforcement, holding that Smith’ s conditional reinstate-ment
did not violate the strong regulation-based public policy against
drug use by workers who perform safety-sensitive functions. The
Fourth Circuit affirmed.
Held: Public policy considerations do not require courts to refuse to enforce an arbitration award ordering an employer to reinstate an employee
truck driver who twice tested positive for marijuana. Pp. 3–9.
(a) The Court assumes that the collective-bargaining agreement itself calls for Smith’s reinstatement, as the parties have granted the
arbitrator authority to interpret the meaning of their contract’s language,
including such words as “just cause,” see Steelworkers v. Enterprise
Wheel & Car Corp., 363 U. S. 593, 599, and Eastern does not
claim here that the arbitrator acted outside the scope of his contractually
delegated authority, see, e.g., Paperworkers v. Misco, Inc., 484
U. S. 29, 38. Since the award is not distinguishable from the contractual
agreement, the Court must decide whether a contractual reinstatement
requirement would fall within the legal exception that
makes unenforceable “a collective bargaining agreement that is contrary
to public policy.” W. R. Grace & Co. v. Rubber Workers, 461 U. S.
757, 766. Any such policy must be “explicit,” “well defined,” and “dominant,”
and it must be “ascertained by reference to the laws and legal
precedents, not from general considerations of supposed public interests.”
Ibid. The question is not whether Smith’s drug use itself violates
public policy, but whether the agreement to reinstate him does
so. Pp. 3–5.
(b) A contractual agreement to reinstate Smith with specified conditions does not run contrary to public policy. The District Court correctly
articulated the standard set out in W. R. Grace and Misco and
applied that standard to reach the right result. The public policy exception
is narrow and must satisfy the principles set forth in those
cases. Moreover, where two political branches have created a detailed
regulatory regime in a specific field, courts should approach
with particular caution pleas to divine further public policy in that
area. Eastern asserts that a public policy against reinstatement of
workers who use drugs can be discerned from an examination of the
Omnibus Transportation Employee Testing Act of 1991 and DOT’s implementing
regulations. However, these expressions of positive law
embody not just policies against drug use by employees in safetysensitive
transportation positions and in favor of drug testing, but
also include a Testing Act policy favoring rehabilitation of employees
who use drugs. And the relevant statutory and regulatory provisions
must be read in light of background labor law policy that favors determination
of disciplinary questions through arbitration when chosen
as a result of labor-management negotiation. See, e.g., California
Brewers Assn. v. Bryant, 444 U. S. 598, 608. The award here is not
contrary to these several policies, taken together, as it does not condone
Smith’s conduct or ignore the risk to public safety that drug use by
truck drivers may pose, but punishes Smith by placing conditions on
his reinstatement. It violates no specific provision of any law or
regulation, but is consistent with DOT rules requiring completion of
substance-abuse treatment before returning to work and with the
Act’ s driving license suspension requirements and its rehabilitative
concerns. Moreover, the fact that Smith is a recidivist is not sufficient
to tip the balance in Eastern’s favor. Eastern’s argument that DOT’ s
withdrawal of a proposed “recidivist” rule leaves open the possibility
that discharge is the appropriate penalty for repeat offenders fails
because DOT based the withdrawal, not upon a determination that a
more severe penalty was needed, but upon a determination to leave
in place other remedies. The Court cannot find in the Act, the regulations,
or any other law or legal precedent an explicit, well defined,
dominant public policy to which the arbitrator’s decision runs contrary.
Pp. 5–9.
188 F. 3d 501, affirmed.
BREYER, J., delivered the opinion of the Court, in which REHNQUIST,
C. J., and STEVENS, O’ CONNOR, KENNEDY, SOUTER, and GINSBURG, JJ.,
joined. SCALIA, J., filed an opinion concurring in the judgment, in
which THOMAS, J., joined.
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