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The South Prairie Construction Co. v. Local No. 627, International Union of Operating Engineers, AFL-CIO case in 1975 involved a dispute over labor practices between the construction company and the union representing its employees. The Supreme Court ruled that an employer could not be compelled to arbitrate grievances under a collective bargaining agreement after it had expired, even if some provisions of the contract were still operative due to ongoing negotiations for a new agreement or other reasons such as "status quo" clauses meant to maintain certain conditions until a new contract is agreed upon. This decision was based on Section 301(a) of Labor Management Relations Act which allows federal courts jurisdiction over disputes involving collective bargaining agreements but does not mandate arbitration post-expiration.
In the dissenting opinion for South Prairie Construction Co. v. Local No. 627, International Union of Operating Engineers, AFL-CIO et al., Justice William O. Douglas argued that the majority's decision was a departure from established precedent regarding labor disputes and arbitration agreements under Section 301(a) of the Labor Management Relations Act (LMRA). He contended that previous rulings had consistently held that federal courts should not intervene in such matters unless there is clear evidence of fraud or bad faith on part of arbitrators or if an award goes beyond what parties have agreed to arbitrate. In this case, he believed no such conditions were present and thus disagreed with the court's intervention to set aside an arbitration award favoring union members over their employer based on alleged procedural irregularities during arbitration proceedings.