Maxwell MacMillan Co., Inc. v. DISTRICT 65, UAW
The plaintiff, Macmillan, sought to stay arbitration initiated by District 65 concerning employee layoffs following Macmillan's acquisition of Prentice-Hall assets. District 65 argued that the layoffs breached an agreement to use seniority in layoff decisions, stemming from Prentice-Hall's unilaterally implemented final offer after its collective bargaining agreement expired. Macmillan contended there was no formal contract to arbitrate, as District 65 had never formally accepted Prentice-Hall's offer in writing. The court, however, ruled that District 65's continuation of work after Prentice-Hall's final offer constituted acceptance by conduct, creating an enforceable interim agreement. Consequently, the court granted District 65's motion for summary judgment, denying Macmillan's, and directed the parties to proceed with arbitration.