Dow Electric, Inc. v. International Brotherhood of Electrical Workers, Local Union No. 910
Plaintiff Dow Electric Inc. sought to vacate a Labor-Management Committee's award for violating collective bargaining agreements, while Defendant Local Union 910 IBEW counterclaimed for confirmation. The dispute centered on whether Dow Electric Inc. effectively terminated its collective bargaining authority with the Association before the 2000-2003 Collective Bargaining Agreement (CBA) came into effect. The Court found that Plaintiff's July 31, 1998, letters unequivocally terminated the Association’s collective bargaining authority, and subsequent correspondence did not retract this. Therefore, the 2000-2003 CBA did not bind Plaintiff, and the Committee lacked jurisdiction over grievances based on it. The Court granted Plaintiff's motion for summary judgment regarding the 2000-2003 CBA award, vacating the $991,629.89 award. However, the Court affirmed the Committee's $63,011.48 award for violations of the 1997-2000 CBA, ruling that disputes based on acts prior to an agreement's expiration can still be arbitrated, and the awards for interest, liquidated damages, and back pay were plausibly grounded in the CBA.