Graphic Arts International Union v. Oakland National Engraving Co.

Graphic ArtsInternational Union, Local No. 280 (the Union) appeals from an order denying its petition to compel arbitration and entering judgment in favor of respondent, Oakland National Engraving Company (the Employer). The trial court reached the merits of what it perceived to be the dispute between the parties, finding in favor of the Employer. It held that to the extent the petition raised a representation issue, that issue was within the exclusive jurisdiction of the National Labor Relations Board (NLRB). It also ruled that the petition was barred by the statute of limitations. We reverse the decision below because (1) the ruling on the statute of limitations was erroneous as a matter of law; (2) a trial court in ruling upon a petition to compel arbitration must not reach the merits of an alleged dispute but, rather, must determine only the threshold question of whether an arbitrable controversy exists; and (3) the petition herein contained only conclusory allegations that such a dispute existed which were insufficient to enable a court to properly determine either whether an arbitrable controversy existed or whether an issue raised was within the exclusive…