United Natural Foods, Inc. v. Teamsters Local 120

CourtDistrict Court, D. Minnesota
DecidedMay 26, 2021
Docket0:21-cv-01174
StatusUnknown

This text of United Natural Foods, Inc. v. Teamsters Local 120 (United Natural Foods, Inc. v. Teamsters Local 120) is published on Counsel Stack Legal Research, covering District Court, D. Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United Natural Foods, Inc. v. Teamsters Local 120, (mnd 2021).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

UNITED NATURAL FOODS, INC. and Case No. 21-CV-1174 (NEB/ECW) SUPERVALU, INC.,

Plaintiffs, ORDER ON MOTION FOR v. PRELIMINARY INJUNCTION

TEAMSTERS LOCAL 120,

Defendant.

On May 13, 2021, United Natural Foods, Inc., and Supervalu, Inc. (collectively, “UNFI”), moved for an expedited preliminary injunction. (ECF No. 7.) The Court granted that motion on May 19, 2021. (ECF No. 23.) The Court now provides the findings and legal conclusions in support of its decision. Teamsters Local 120 (“Union”) accused UNFI of favoring non-union employees at a wholesale grocery warehouse. After the parties could not settle the dispute through the informal process set forth in the collective bargaining agreement (“CBA”), the Union moved eight grievances about the issue to eight separate arbitrations before four different arbitrators. At the first arbitration, the parties presented opening statements, arguing in part over claimed procedural defects with the process of choosing the arbitrator. The Union refused to go forward with the first arbitration after opening statements because UNFI reserved its rights to challenge the alleged procedural defects in federal court. The Union also canceled the next five arbitrations. It left in place the final two arbitrations, both before arbitrator Richard Miller, leading UNFI to accuse the Union of arbitrator-

shopping. UNFI sued, arguing that the Union had breached the CBA by failing to follow its arbitration requirements. UNFI also sought an injunction staying the final two arbitrations pending resolution of its claims before the Court. The Court granted the

motion at the hearing and now provides this opinion explaining its rationale. BACKGROUND1 I. Arbitration and the Grievance Resolution Provisions The CBA has a detailed process for resolving disputes, or “grievances,” that arise

between UNFI and the Union. The process is set forth in Articles 15 and 16 of the CBA. Article 15 prescribes an informal, multistep process that ends in attempted resolution before a four-member Labor-Management Council. (ECF No. 1-1 (“CBA”) art. 15.02.)

Outside legal counsel may not participate in the first few steps of the informal process. (Id.) If the Labor-Management Council cannot resolve the dispute, the parties may pursue arbitration. (Id. art. 15.03.) If UNFI or the Union fails to follow the timelines of the informal resolution process (which the parties can alter only by written agreement), the

party that fails to prosecute loses. (Id. arts. 15.04, 15.05.)

1 Although the Union accuses UNFI of presenting “an incomplete and distorted” version of the facts, (ECF No. 17 at 1), the Union presents no factual material that contradicts either the Complaint or UNFI’s declarations. The Court therefore sets forth the facts as presented by the Complaint and the supporting records provided by UNFI. Article 16 of the CBA covers arbitration of grievances, and, like Article 15, it sets forth strict timelines. If the parties cannot resolve the issue through the informal process

and instead pursue arbitration, the party seeking arbitration must do so within 30 calendar days from a decision from the Labor-Management Council. (Id. art. 16.01.) When the party notices arbitration, it must request a panel of seven arbitrators. It then has ten

days to begin striking arbitrators.2 (Id. arts. 16.01, 16.02.) Within 30 days of selecting an arbitrator, the parties must agree on an arbitration date; the arbitrator must “issue a decision” within 30 days of the submission of the parties’ briefs. (Id. art. 16.03.) This

timeline can only be extended by written agreement of the parties. (Id. art. 16.05.) The CBA also addresses the scope of the arbitrator’s authority under it. An arbitrator hearing a grievance “shall have jurisdiction and authority only to interpret and apply the express provisions of th[e CBA]. The Arbitrator shall not have authority to alter,

amend, subtract from, add to, or otherwise modify any of the terms of th[e CBA].” (Id. art. 16.04.) And of vital importance to this case, the CBA states that “[a]ll grievances noticed for arbitration shall, unless settled, be heard by an arbitrator.”(Id. art. 16.01.)

II. The Disputes Between June 2020 and September 2020, the Union submitted eight grievances against UNFI. (ECF No. 1 (“Compl.”) ¶ 1(a), (b).) These grievances related to allegations

2 The moving party strikes first, then the non-moving party, until one arbitrator remains, who will hear the case. (CBA art. 16.02; ECF No. 1 ¶ 78.) that UNFI favored non-union, temporary employees over union employees. (E.g., id. ¶¶ 18, 27.) On July 30, 2020, the Labor-Management Council was unable to resolve the

first grievance (“Grievance 461”). (Id. ¶¶ 19–20.) The Union’s Business Agent timely moved Grievance 461 to arbitration per Article 16 of the CBA; the Union simultaneously requested a panel of arbitrators. (Id. ¶¶ 22, 93.) Similarly, the Labor-Management Council

could not resolve the second grievance (“Grievance 523”), which also went to arbitration. (Id. ¶¶ 27–30.) This process occurred for six more grievances, all relating to UNFI favoring non-union, temporary workers over union workers. (Id. ¶¶ 35–74.)

After moving Grievance 523 to arbitration, on August 3, 2020, the Union requested a panel of arbitrators, which it received. (Id. ¶ 85.) The Union did not begin striking arbitrators within 10 days (as was required by the CBA). (Id. ¶ 86; see CBA art. 16.02.) The Union then requested a second panel of arbitrators; again, it failed to begin striking

arbitrators within 10 days. (Compl. ¶¶ 88–89.) The Union also requested two panels of arbitrators for Grievance 461 and similarly failed to begin striking arbitrators from either. (Id. ¶ 93.) UNFI sought to consider both Grievance 523 and Grievance 461 resolved in its

favor as a result of the Union’s failure to follow the CBA’s procedures. (Id. ¶¶ 90–92, 94– 97.) The Union and UNFI disagreed over the proper way forward, given that they had two separate panels of arbitrators for Grievance 461 and Grievance 523. (Id. ¶¶ 98–101.)

Each side proposed possible solutions. (Id. ¶¶ 102–20.) Ultimately, UNFI agreed to use the first panels for both Grievance 461 and Grievance 523, subject to its reservation of rights to raise the procedural issues in court. (Id. ¶¶ 121, 141; see id. ¶ 116.) UNFI and the

Union selected Jeffrey W. Jacobs to arbitrate Grievance 523 and Christine Ver Ploeg for Grievance 461.3 (Id. ¶ 121.) UNFI and the Union scheduled arbitration for Grievance 523 for January 18, 2021. (Id. ¶ 129.) The parties also scheduled: Grievance 461 for April 2021

with Arbitrator Ver Ploeg; three more grievances before Arbitrator Jacobs, one each in February, March, and April 2021; one grievance before Arbitrator Laura Cooper in April 2021; and (importantly here) the final two grievances before Arbitrator Richard Miller in

May 2021—one on May 12, the other on May 20. (Id. ¶¶ 1(b), 26, 41, 48, 55, 62, 68, 74.) III. The Arbitration Proceedings Based on UNFI’s reservation of rights, the parties agreed to bifurcate the arbitration proceedings, address the procedural issues first, and only proceed to the

merits if the arbitrator resolved the procedural issues in favor of the Union. (Id. ¶¶ 122– 23, 126–28.) At the January arbitration of Grievance 523 before Arbitrator Jacobs, UNFI and the

Union disputed the issue of the arbitrator’s jurisdiction to issue a binding award due to the existence of two panels of arbitrators. (Id. ¶¶ 131–33; see generally ECF No. 1-2.)

3 There appears to be an error in the Complaint over this issue: it alleges that the parties selected both Arbitrator Jacobs and Arbitrator Ver Ploeg to hear Grievance 523. (Compl.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
United Natural Foods, Inc. v. Teamsters Local 120, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-natural-foods-inc-v-teamsters-local-120-mnd-2021.