Washington Heights-West Harlem-Inwood Mental Health Council, Inc. v. District 1199, National Union of Hospital & Health Care Employees, RWDSU
This case involves a dispute between District 1199, National Union of Hospital and Health Care Employees, and Washington Heights-West Harlem-Inwood Mental Health Council, Inc. The union sought to enforce an arbitration award requiring the Council to rehire and provide back pay to an employee, Edward Lane. The Council cross-moved to vacate the award, arguing that no valid collective bargaining agreement with an arbitration clause existed between the parties. Although the parties had acted under the terms of a proposed agreement for a period, including processing some grievances and wage increases, no formal, signed contract had ever been executed. Citing recent appellate court decisions emphasizing contract formalism over implied intent, the District Court granted the Council's motion to vacate the arbitration award and denied the union's motion to enforce it, concluding that without a signed agreement, there was no contractual duty to arbitrate.