Massachusetts Nurses Ass'n v. North Adams Regional Hospital
Court of Appeals for the First Circuit
1Opinion of the Court
SELYA, Circuit Judge.
This appeal requires us to mull the circumstances in which a union, having successfully arbitrated a grievance, may leverage the award to bypass procedures prescribed by a collective bargaining agreement and obtain direct federal court relief for subsequent episodes of alleged employer misconduct. In the case at hand, the district court thwarted the union’s attempt to short-circuit the grievance process, finding too great a disparity between the facts underlying the initial complaints and those giving rise to the subsequent complaints. After careful consideration, we…
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