Sheet Metal Workers International Association, Local 104 v. Simpson Sheet Metal, Inc. William Simpson Nancy Simpson

Sheet Metal Workers’ International Association, Local Union No. 104 (“the Union”) filed a petition in the district court to confirm an arbitration award against Simpson Sheet Metal, Inc. (“Simpson”). The award established a new collective bargaining agreement (“CBA”) between the Redwood Empire Sheet Metal and Air Conditioning Contractors’ National Association (“Redwood SMACNA”) and the Union. Simpson contended that, due to its withdrawal from Redwood SMACNA prior to negotiations, it was not bound by the arbitration award. The district court confirmed the arbitration award, but struck the interest arbitration clause from the new CBA. The Union timely appealed from this portion of the district court’s judgment. We reverse.

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Simpson and the Union were signatories to a CBA that expired June 30, 1989. The CBA included an interest arbitration clause providing that, if negotiations for renewal of the agreement became deadlocked, the parties would submit the dispute to binding arbitration by the National Joint Adjustment Board (“NJAB”). CBA Art. X, § 8. Under the terms of the CBA, each signatory employer authorized Redwood SMACNA “to act as its collective bargaining representative for…