United Steelworkers of America, afl-cio.clc v. Smoke-Craft, Inc.

Smoke-Craft, Inc. appeals the district court’s summary judgment confirming an arbitration award that upheld a union grievance protesting the employer’s refusal to honor the seniority rights of former strikers. Two unions were jointly certified as the exclusive bargaining agent of Smoke-Craft’s employees. The unions negotiated a collective bargaining agreement with the employer, pursuant to which the grievance arose and was submitted to arbitration by both unions. Settlement negotiations interrupted the arbitration; the arbitration then proceeded with only one of the unions processing the grievance to completion. Smoke-Craft appeals the district court’s summary confirmation of the arbi-tral award on the grounds that genuine issues of material fact remain unresolved and that the union, acting in its individual capacity, had no standing to seek confirmation of the award in the district court. We affirm.

I. FACTS

Smoke-Craft is an Albany, Oregon beef product manufacturer. In 1974, having failed several times to become the exclusive bargaining representative of Smoke-Craft’s employees, the Amalgamated Meat Cutters and Butcher Workmen of North America, AFL-CIO, Local 324 (the Meat…