Michigan Family Resources, Inc. v. Service Employees International Union Local 517m

Nearly a half-century ago, the Supreme Court issued three watershed opinions designed to end the federal courts’ hostility to labor-arbitration awards. See United Steelworkers v. Am. Mfg. Co., 363 U.S. 564, 80 S.Ct. 1343, 4 L.Ed.2d 1403 (1960); United Steelworkers v. Warrior & Gulf Navigation Co., 363 U.S. 574, 80 S.Ct. 1347, 4 L.Ed.2d 1409 (1960); United Steelworkers v. Enter. Wheel & Car Corp., 363 U.S. 593, 80 S.Ct. 1358, 4 L.Ed.2d 1424 (1960). In one of these decisions, the Court stated that “[t]he refusal of courts to review the merits of an arbitration award is the proper approach to…