In the case of W. R. Grace & Co. v. Local Union 759, International Union of the Rubber, Cork, Linoleum & Plastic Workers of America (1982), the Supreme Court ruled on a dispute between W.R Grace and Company and its employees' union over an arbitration award that had been vacated by lower courts due to alleged bias from one arbitrator who failed to disclose his relationship with an organization linked to the union before proceedings began. The Supreme Court held that under federal labor law, if a party involved in arbitration suspects potential partiality or bias in an arbitrator they must object at the outset of proceedings rather than after receiving unfavorable results; otherwise they forfeit their right to challenge it later on grounds of impartiality or corruption unless there is clear evidence showing such misconduct affected fairness during proceedings.

In the dissenting opinion for W. R. Grace & Co. v. Local Union 759, it was argued that the majority's decision to allow a federal court to enforce an arbitration award before all contractual remedies had been exhausted was incorrect and inconsistent with established labor law principles. The dissent emphasized that under Section 301 of the Labor Management Relations Act, courts should only intervene in labor disputes when parties have exhausted their agreed-upon dispute resolution mechanisms - including any appeals processes outlined in their collective bargaining agreement (CBA). In this case, while an arbitrator had ruled in favor of the union, there were still unexhausted appeal procedures within the CBA which could potentially reverse or modify this ruling; thus making judicial enforcement premature and inappropriate at this stage according to dissenters.