Santiago Amaro v. The Continental Can Company

INTRODUCTION

In this case we are confronted with the competing tensions of access to the courts and arbitration. The issue presented is whether an arbitration award on a grievance under a collective bargaining agreement is res judicata of an Employee Retirement Income Security Act (“ERISA”) claim arising out of the same facts. A related issue is whether exhaustion of arbitration procedures for contractual grievances is required prior to bringing a statutory claim under section 510 of ERISA. The district court held that the arbitration award on a contractual grievance adverse to former employees of the Continental Can Company barred their ERISA claims against their former employer. We reverse and remand.

FACTS AND PROCEEDINGS BELOW

The plaintiffs are former employees (“employees”) of the Continental Can Company (“Continental”) who were laid off from the company’s Los Angeles plant between 1976 and the present. The employees’ union representative, United Steel Workers of America (“Union”), filed a grievance on March 5, 1980 alleging that Continental’s layoff of these employees and its correspondent shift of production to other plants violated various provisions of the collective…