In the case of McDonald v. City of West Branch, Michigan et al., 1983, the U.S. Supreme Court ruled that an arbitration award in a labor dispute does not preclude subsequent judicial action under Section 301(a) of the Labor Management Relations Act (LMRA). The plaintiff, Richard McDonald was a police officer who had been discharged by his employer, the city of West Branch. His union filed grievances on his behalf and won an arbitration decision ordering his reinstatement with back pay. However, he later sued for damages under section 301(a), claiming wrongful discharge and violation of collective bargaining agreement rights. The District Court dismissed this claim as barred by res judicata due to prior arbitration proceedings but was reversed by Sixth Circuit court stating that federal policy favors arbitral resolution which doesn't bar further litigation unless parties agreed so explicitly in their contract. The Supreme Court held that while it encourages settlement through arbitration processes when possible; however such decisions do not necessarily prevent future legal actions if they are based on different claims or issues than those addressed during initial proceedings - thus allowing McDonald's lawsuit to proceed.

In the dissenting opinion for McDonald v. City of West Branch, Michigan, et al., Justice Brennan disagreed with the majority's view that a public employee could not recover damages under 42 U.S.C. §1983 if he or she had an opportunity to arbitrate a dispute through collective bargaining agreement procedures but chose not to do so. He argued that this decision was inconsistent with previous rulings and undermined Congress' intent when it enacted Section 1983 - to provide broad protection against constitutional violations by state actors. The justice also contended that arbitration is fundamentally different from judicial proceedings in terms of procedural protections and scope of review, thus should not be considered as equivalent remedies for constitutional rights violations.