In the United Steelworkers of America v. Enterprise Wheel & Car Corp., 1959, the Supreme Court ruled in favor of the union and upheld an arbitrator's decision to reinstate five employees who had been fired for participating in a wildcat strike. The company argued that it was not bound by this decision because it exceeded the scope of issues agreed upon for arbitration under their collective bargaining agreement with the union. However, Justice Douglas delivered a unanimous opinion stating that courts should defer to arbitrators' interpretations unless they are completely unfounded or irrational. He emphasized that while courts may disagree with an arbitrator’s interpretation, they must respect his judgment as long as he is even arguably construing or applying the contract and acting within his authority. This case established important precedent regarding judicial review of labor arbitration awards.

In the dissenting opinion for United Steelworkers of America v. Enterprise Wheel & Car Corp., Justice Frankfurter argued that the court majority had overstepped its bounds by enforcing an arbitration award without sufficient scrutiny. He contended that while courts should respect and enforce labor arbitration decisions, they must also ensure these decisions are rooted in the collective bargaining agreement between parties. In this case, he believed there was no evidence to suggest that a 'no-strike' clause existed within such an agreement or could be inferred from it; thus, he disagreed with imposing penalties on workers who participated in strikes. Furthermore, he criticized his colleagues for not providing clear guidance on when courts can review arbitral awards and expressed concern about potential abuse of power by arbitrators if their decisions were left unchecked.