Sauer

The California Department of Rehabilitation (DOR) and the United States Department of Education appeal from the district court’s decision enforcing a 2008 arbitration award issued pursuant to 20 U.S.C. § 107d-l(a) of the Randolph-Sheppard Vending Stand Act (the Act). We have jurisdiction pursuant to 28 U.S.C. § 1291 , and we reverse.

I

Some familiarity with the structure of the Randolph-Sheppard Act and the manner in which it provides for resolution of disputes is necessary to understand the sequence of events in this case. We briefly provide the relevant background.

A

The Randolph-Sheppard Act establishes a cooperative program between the federal government and the states to assist blind persons who wish to operate vending facilities on federal property. See 20 U.S.C. § 107 . The stated purposes of the Act are “providing blind persons with remunerative employment, enlarging the economic opportunities of the blind, and stimulating the blind to greater efforts in striving to make themselves self-supporting.” § 107(a). The Rehabilitation Services Administration within the Department of Education administers the Act with the help of state agencies designated by the…