In the case of Major League Baseball Players Association v. Steve Garvey, former baseball player Steve Garvey appealed to the Supreme Court after an arbitrator ruled against him in a dispute over funds distributed following a collusion agreement between team owners. The Ninth Circuit Court had previously overturned this ruling, stating that it was made "in manifest disregard of the law." However, the Supreme Court reversed this decision and reinstated the original arbitration award. They concluded that federal courts have no business reviewing labor-arbitration decisions on grounds other than those set forth by Congress in §301 of Labor Management Relations Act (LMRA). This is because such reviews would undermine collective bargaining agreements' finality provision and encroach upon what is primarily a contractual matter reserved for resolution within framework provided by national labor laws.

In the dissenting opinion for Major League Baseball Players Association v. Steve Garvey, Justice John Paul Stevens argued that the Court of Appeals had overstepped its boundaries by reevaluating evidence and making independent determinations about witness credibility - a role reserved for arbitrators. He contended that it was not within their jurisdiction to decide whether or not substantial evidence supported the arbitrator's decision; rather, they should have deferred to the expertise and judgment of the arbitrator as long as his decision drew from "the essence" of collective bargaining agreement between parties involved. In this case, he believed that standard had been met. Therefore, in his view, Garvey should have received compensation per original arbitration award without court interference.