Eastern Associated Coal Corp. v. Mine Workers, 531 U.S. 57 (2000)

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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's 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 reinstatement 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. 61-67.

(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 "as-


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