Rowry v. University of Michigan

Reluctantly, I concur in the result reached by the majority. I write separately to express my concern that application of a limitation period of six years, rather than six months, will seriously undermine state and federal policies favoring the prompt resolution of labor disputes.

In its analysis, the majority concludes that the six-year period generally applicable to contract actions1 is the appropriate limitation period to apply to this plaintiff’s action to "enforce” a labor *13arbitration award. However, this case involves more than a simple breach of contract or a straightforward refusal to…