Collective Bargaining Agreement – Arbitration

7^th Circuit Court of Appeals

Case Name: United Natural Foods, Inc. v. Teamsters Local 414

Case No.: 22-1469

Officials: Sykes, Chief Judge, and Rovner and Jackson – Akiwumi, Circuit Judges.

Focus: Collective Bargaining Agreement – Arbitration

United Natural Foods, Inc., and its corporate affiliates filed suit against Teamsters Local 414 contending that the Local breached its collective bargaining agreement with the company by initiating two strikes at United Natural’s Fort Wayne, Indiana distribution center. The question presented in this appeal is whether United Natural is compelled by the grievance and arbitration provisions of the collective bargaining agreement to arbitrate this claim.  The arbitration procedure is focused exclusively on employee-initiated grievances and does not apply to employer-initiated grievances. The arbitration clause is not reasonably susceptible to an interpretation that includes an employer-initiated dispute regarding the CBA’s terms and thus, United Natural is not compelled to arbitrate this claim. See United Natural Foods, Inc. v. Teamsters Local 414, 2022 WL 767165 (N.D. Ind. Mar. 14, 2022).

Affirmed.

Decided 01/31/23

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