International Longshoremen's Ass'n v. Hanjin Container Lines, Ltd.
The International Longshoremen’s Association (ILA) petitioned the District Court to confirm and enforce arbitration awards totaling $21,000 against Hanjin Container Lines (HCL) and Hanjin Shipping Co., Ltd. (Hanjin). These awards stemmed from violations of the “Rules on Containers,” which are part of the ILA-New York Shipping Association (NYSA) collective bargaining agreement, mandating the use of ILA longshoremen for container work. Hanjin challenged the awards, asserting that HCL was not bound by the agreement for earlier awards and that the Rules had been declared illegal by the Federal Maritime Commission (FMC). The Court granted ILA’s petition, determining that Hanjin waived jurisdictional objections by participating in arbitration and that various stays issued by the FMC and the D.C. Circuit Court of Appeals kept the Rules in effect during the period the awards were issued.