Opinion by Judge REINHARDT; Concurrence by Judge MICHAEL DALY HAWKINS; Dissent by WHYTE.

Former professional baseball player Steve Garvey (“Garvey”) appeals the district court’s denial of his Amended Motion to Vacate Arbitration Award. Garvey made Jiis motion after an arbitrator confirmed the Major League Baseball Players Association’s (the “Association”) denial of Garvey’s claim for damages from a settlement fund which was established after arbitration decisions finding that the Major League Baseball Clubs (the “Clubs”) had engaged in collusion in the market for free agent services. Garvey contends that the district court committed reversible error by denying his motion to vacate for lack of subject matter jurisdiction with an alternative denial on the merits.

I. BACKGROUND

A. The Grievances, Settlement Agreement and Framework

In 1986, 1987 and 1988, the Association filed grievances against the Clubs, alleging that the Clubs had violated the Collective Bargaining Agreement (“CBA”) between the Clubs and the Association by engaging in collusion in the market for free agent services after the 1985, 1986 and 1987 baseball seasons. On December 21, 1990, after arbitration decisions finding that the Clubs had engaged in collusion and caused extensive damage to numerous players, the Association and the Clubs entered into a Global Settlement Agreement (“Settlement Agreement”) to resolve the grievances. Pursuant to the Settlement Agreement, *583 the Clubs established a fund of $280 million to be distributed to damaged players.

The Settlement Agreement provided that the Association would design a “Framework” “to establish an appropriate process for evaluation and determination of individual claims” for money from the fund. The Association issued a proposed Framework for resolution of claims to an independent arbitration panel for its consideration, and any player was permitted to file objections. On September 14, 1991, after hearings on players’ objections to the Framework, the arbitration panel approved the Framework with amendments.

Players claiming damages from the collusion were required to file their claims by May 20, 1991. 3 The Association then began evaluating the claims pursuant to the Framework.

Under the Framework, as the Association concluded the evaluation of individual players’ claims for a particular season or seasons, it was required to propose an overall distribution plan or a partial distribution plan for the claims relating to that season or seasons. Each recommended plan was then submitted to player claimants and the arbitrator. Player claimants or their agents could object to the Association’s distribution plan recommendations, and the Association then responded by providing the arbitrator with a written statement of how it arrived at its proposed damage evaluation for that particular player. An objecting player claimant could then request oral argument before the arbitrator.

The Framework defines the responsibility and authority of the arbitrator with regard to review of a distribution plan as follows:

(Emphasis in original).

B. The Standard Under the Framework for Assessing Lost Contract Extension Claims

At issue in this appeal is Garvey’s claim for damages resulting from an alleged lost contract extension for the 1988 and 1989 baseball seasons which Garvey claims resulted from the Clubs’ collusion. Garvey’s claim, which was based on his 1987 salary, *584 was approximately $3,000,000 for the two year period.

The Framework sets forth, at Section II, the standard for a player’s recovery of damages for an alleged lost contract extension, as follows:

(Emphasis in original).

The Framework then sets forth at Section V, “Evaluation of Individual Player Claims,” the following factors to be considered by the arbitrator, where applicable, in evaluating, all player claims for money damages:

The arbitrator further addressed the standard regarding lost contract extension claims in his February 14, 1994 award regarding Plan Distribution II:

The arbitrator reiterated this standard in later denying Garvey’s claim, further explaining that “in each of the few contract extension claims recognized it was ‘shown that the club in question actually made a specific offer of a contract extension only to later summarily withdraw that offer pursuant to the scenario of the collusion program.’ ”

C. The Garvey Arbitration

Garvey’s contract with the San Diego Padres covered the years 1983-1987. Garvey claimed damages from the settlement fund based on his allegation that the Padres would have given him a two-year *585 contract extension for the years 1988 and 1989, but did not because of collusion.

On February 8, 1996, the Association released its proposed distribution plan covering the 1988 Claims. The plan awarded nothing to Garvey on his claim. In the period of almost ten years between the time the first collusion grievance was filed and the issuance of the 1988 distribution plan, Garvey did not present the Association with any evidence that the Padres actually offered to extend his contract. Garvey objected, and a hearing was held before the arbitrator on July 2,1996. 4

At the arbitration hearing, Garvey testified that the Padres made a pre-collusion offer in September 1985 to extend his contract for the 1988 and 1989 seasons, and that the Padres subsequently withdrew that offer because they had begun colluding with other teams. Garvey presented at the July 2, 1996 hearing, for the first time, a June 28, 1996 letter from Ballard Smith, the President/CEO of the Padres in the period 1979-1987. Smith’s letter states that before the end of the 1985 season Smith made an offer to Garvey to extend his contract through the 1989 season, but that the Padres would not thereafter negotiate with Garvey due to their policy of collusion. Smith’s letter states that “[tjhere is no question in my mind that the reason the Padres withdrew their offer to Steve Garvey to sign a contract extension with the Padres was due to the collusion among the Clubs.”

At the Association’s request, the arbitrator granted a 21-day recess, requesting that both parties initiate a diligent effort to identify and produce documentation that could assist him in determining “what actually took place” from 1984 on with regard to the potential of an extension. After the recess, the Association submitted to the arbitrator the following additional evidence:

In his May 1, 1997 award addressing fifty-eight players’ claims, the arbitrator sustained several players’ objections to the plan distribution, but denied Garvey’s. The arbitrator’s award dedicated over five pages to discussion of Garvey’s claim and the Association’s denial of it. The arbitrator’s discussion noted Garvey’s testimony regarding the circumstances of the alleged offer and withdrawal. The arbitrator cited the letter from Smith and quoted its assertion that the offer was withdrawn due to collusion. The arbitrator wrote that this statement, “taken on its face, appears to support the position of Garvey advanced in this proceeding.” The arbitrator nonetheless concluded that “[tjhere exists, however, substantial doubt as to the credibility of the statements in the Smith letter.” The arbitrator quoted Smith’s testimony from the 1986 collusion proceedings in which Smith had stated that the Padres were not in fact interested in continuing Garvey’s contract in 1986 and that there had been no collusion. The arbitrator determined that

The arbitrator found that, “[w]hile Garvey and Smith may well have discussed the possibility of a contract extension,” the scenario presented “does not meet the test established by the award of February 14, 1994,” namely, the requirement of a “specific offer of an extension” made prior to collusion “only to thereafter be withdrawn when the collusion scheme was initiated.” The arbitrator concluded that

D. The District Court Proceeding

Garvey filed a Motion .to Vacate Arbitration Award in district court in response to the arbitrator’s denial of his claim, asserting jurisdiction under 28 U.S.C. § 1332 (a)(1) and Section 10 of the Federal Arbitration Act. However, in his brief in opposition to the Association’s motion to dismiss, Garvey added a further allegation of jurisdiction under Section 301 of the LMRA, which provides, at subsection (a):

*587 29 U.S.C. § 185 (a). The court allowed Garvey leave to amend to properly assert jurisdiction.

Garvey thereafter filed, on November 3, 1997, an Amended Motion to Vacate Arbitration Award, again asserting jurisdiction under Section 301 of the LMRA. Garvey’s motion argued that the award should be vacated because the arbitrator’s' decision did not draw its essence from a collectively bargained agreement and exceeded the arbitrator’s authority.

In a November 24, 1997 tentative ruling, the district court stated that it was inclined to dismiss Garvey’s amended motion for lack of subject matter jurisdiction and, in the alternative, that it was inclined to deny the motion on the merits based on a proper application of the standard of review of the arbitrator’s decision. The court ruled from the bench during the November 24, 1997 oral argument, stating that “it’s not an easy case because of subject matter jurisdiction. But as I said in my tentative, the movant failed to meet the requirement of jurisdiction under 29 USC 185.” The court continued that, “[ajccord-ingly, the matter should be dismissed for want of subject matter jurisdiction. But then to go on further, the court doesn’t feel comfortable in upsetting the arbitrator’s decision. He heard the case, and he made his decision, and I think he was correct.” The court’s December 8, 1997 order denied Garvey’s motion “for the reasons stated on the record on November 24, 1997.” Garvey thereafter filed his notice of appeal.

II. ANALYSIS

A. Jurisdiction

The question of whether a district court has jurisdiction over a matter is reviewed de novo. See Wilson v. A.H. Belo Corp., 87 F.3d 393, 396 (9th Cir.1996). Jurisdiction is proper under LMRA § 301(a) where (1) the suit is based on an alleged breach of contract between an employer and a labor organization and (2) the resolution of the lawsuit is focused upon and governed by the terms of the contract. See Painting and Decorating Contractors Ass’n of Sacramento, Inc. v. Painters and Decorators Joint Committee of the East Bay Counties, Inc., 707 F.2d 1067, 1071 (9th Cir.1983). Section 301 is “not to be given a narrow reading.” Smith v. Evening News Ass’n, 371 U.S. 195, 199 , 83 S.Ct. 267, 270 , 9 L.Ed.2d 246 (1962).

Individual employees can invoke Section 301 jurisdiction to assert their rights under an agreement between an employer and a labor organization. See id. at 200-201 , 83 S.Ct. at 270 . Moreover, a “contract” under Section 301 can extend to documents beyond the collective bargaining agreement itself, as separate documents are often used to define the rights and obligations contemplated in a single contract. Alvares v. Erickson, 514 F.2d 156, 161 (9th Cir.1975). The court in Alvares therefore found that the word “contract” as it appears in Section 301(a) encompassed the provisions of a welfare trust which had been established as a supplement to and referred to in a collective bargaining agreement. See id. Likewise, a suit regarding individual rights to pension benefits that are deemed to “arise” from a collective bargaining agreement falls under Section 301(a). See Rehmar v. Smith, 555 F.2d 1362, 1367 (9th Cir.1976). Similarly, in O’Hara v. District No. 1-PCD, 56 F.3d 1514 (D.C.Cir.1995), the D.C. Circuit held that union members’ claims that the union breached the collective bargaining agreement by failing to distribute moneys which the union received pursuant to an arbitration award fell under Section 301.

Garvey’s motion to vacate the arbitration award alleges that the arbitrator violated the Framework when he denied Garvey’s claim. Although, taken alone, the Framework is not an agreement between an employer and a labor organization, it is a set of rules and guidelines developed pursuant to a settlement agreement between an employer and a labor *588 organization, designed as a means to distribute moneys paid as a result of the employer’s established breach of a collective bargaining agreement. As in Reli-mar, the right which Garvey seeks to vindicate, namely, his right to payment for alleged damages caused by collusion, “arises from” the CBA, for his right to be free from the effects of collusion is founded in the CBA, Garvey claims that his request for moneys from the settlement fund was wrongfully denied. His claim is premised on rights set forth in the CBA and the Settlement Agreement which followed it, and is thus properly brought under Section 301 of the LMRA.

B. The Arbitration Award

In reviewing the merits of Garvey’s challenge to the arbitrator’s award, we start with the proposition that judicial review of an arbitrator’s decision in a labor dispute is extremely limited. Our deferential approach to judicial review found its first important expression in three 1960 Supreme Court cases that have come to be known as the “Steelworkers Trilogy.” See Steelworkers of America v. American Manufacturing Co., 363 U.S. 564 , 80 S.Ct. 1343 , 4 L.Ed.2d 1403 (1960); United Steelworkers of America v. Warrior & Gulf Navigation Co., 363 U.S. 574 , 80 S.Ct. 1347 , 4 L.Ed.2d 1409 (1960); United Steelworkers of America v. Enterprise Wheel & Car Corp., 363 U.S. 593 , 80 S.Ct. 1358 , 4 L.Ed.2d 1424 (1960). In those eases, the Court explained that a collective bargaining agreement is “more than a contract; it is a generalized code to govern a myriad of cases which the draftsmen cannot wholly anticipate.” Warrior & Gulf Navigation Co., 363 U.S. at 578, 80 S.Ct. 1347 . The Court went on to state that because the arbitrator is the .one chosen to implement the collective bargaining agreement’s system of self-government, “[i]t is the arbitrator’s construction [of the agreement] which was bargained for; and so far as the arbitrator’s decision concerns construction of the contract, the courts have no business overruling him because their interpretation of the contract is different from his.” Enterprise Wheel & Car Corp., 363 U.S. at 599, 80 S.Ct. 1358 . Accord Federated Dept. Stores v. United Food & Comm. Workers Union, Local 1442, 901 F.2d 1494 , 1496 (9th Cir.1990). More recently, the Court has reiterated the deference due to an arbitrator’s award: “[A]s long as the arbitrator is even arguably construing or applying the contract and acting within the scope of his authority, that a court is convinced he committed serious error does not suffice to overturn his decision.” United Paperworkers Intl. Union, AFL-CIO v. Misco, Inc., 484 U.S. 29, 38 , 108 S.Ct. 364 , 98 L.Ed.2d 286 (1987).

In Enterprise Wheel & Car Corp., the Supreme Court set forth one of the exceptions to the general rule of outright refusal to review the merits of arbitrators’ awards. The general rule, the Court noted, is inapplicable when an arbitrator “dispense^] his own brand of industrial justice.”. 363 U.S. at 597, 80 S.Ct. 1358 . In those instances — instances in which, by definition, an arbitrator’s award draws no legitimacy from the collective bargaining agreement — a court has no choice but to refuse enforcement of the award. Over the years, we have formulated this exception in various ways. See, e.g., SFIC Properties, Inc. v. International Assn. of Machinists & Aerospace Workers, Dist. Lodge 94, 103 F.3d 923, 925 (9th Cir.1996) (stating that the exception applies “when the award does not ‘draw its essence from the collective bargaining agreement’ ”); Sheet Metal Workers v. Arizona Mechanical & Stainless, Inc., 863 F.2d 647 , 653 (9th Cir.1988) (suggesting that the exception applies where the award does not “represente ] a plausible interpretation of the contract”). Although the formulations have been various, the underlying rule has remained unchanged. We overturn an arbitrator’s award only when it is clear from the arbitral opinion or award that the arbitrator did not base his decision on an interpretation of the collective bargaining agreement or that he disregarded what the *589 parties put before him and instead followed his own whims or biases. 5

Even this narrow exception to the rule of deference comes with a caveat: we will not overturn an arbitrator’s decision on the ground that his written explanation of an award fails to show how the award is based on an interpretation of the collective bargaining agreement. Because arbitrators generally operate in an ad hoc manner with informal procedures, “[w]e do not require labor arbitrators to make the sorts of explicit or exhaustive ‘findings of fact’ we demand of district courts; likewise, the reasons for arbitral rulings need not be spelled out in detail. Indeed, ‘[a]rbitrators have no obligation ... to give their reasons for an award’ at all.” Stead Motors, 886 F.2d at 1206 (quoting Enterprise Wheel & Car Corp., 363 U.S. at 598, 80 S.Ct. 1358 ). Thus, ambiguity in an opinion that accompanies an award, or a lack of any real opinion at all, is not sufficient to permit an inference that the arbitrator exceeded his authority. See Enterprise Wheel & Car Corp., 363 U.S. at 598, 80 S.Ct. 1358 ; Stead Motors, 886 F.2d at 1208. When an arbitrator does give reasons for a decision, however, we must accept those reasons as the basis for the award. To do otherwise would undermine the system of deference that governs our method of review.

In the present case, accepting Arbitrator Roberts’s reasons as the basis for the award leads us inexorably to the conclusion that in reaching his decision the arbitrator “dispensed his own brand of industrial justice.” 6 The arbitrator denied Garvey’s claim for the reason that Ballard Smith’s “testimony” regarding Garvey’s contract negotiations at the 1996 individual claim proceeding was “in stark contradiction” to the statements Smith made in his capacity as the San Diego Padres’ President and Chief Executive Officer at the infamous 1986 collusion hearing. Based on this contradiction, the arbitrator credited the version of events described by Smith at the earlier collusion hearing and, accordingly, concluded that both Smith’s and Garvey’s testimony at the later proceeding was false. To understand why this decision can only be explained as an attempt by the arbitrator to dispense his own brand of industrial justice, we must review the context in which he reached his extraordinary conclusion.

As explained above, the present individual claim proceeding arose out of an earli *590 er finding by a panel chaired by the same arbitrator, Thomas Roberts, that the baseball club owners had colluded over a period of time to depress player salaries and deprive highly paid players such as Garvey of their economic rights. After the club owners were found hable, they settled the damages claim by setting aside two hundred eighty million dollars for the benefit of the players who were the victims of their collusive activities. The arbitrators reached their finding of collusion following hearings in which various owners, including Smith, testified under oath that no collusion of any kind had occurred. During those hearings, Smith was asked to explain what reason there could possibly be, absent collusion, for the Padres’ decision not to re-sign Garvey. In response, Smith stated that the Padres were simply no longer interested in Garvey’s services as a player because the “Club [was] at a different point” than it had been at when it signed him in 1982. Smith also testified that the Padres’ contract decisions during the period of alleged collusion were the product of nothing “but [his] own individual club judgment about the best interests of the Padres.” After considering Smith’s testimony and similar testimony from other owners, the arbitrators, headed by Chairman Roberts, rejected the owners’ contentions and held that they had indeed colluded to depress player salaries and deprive players of their rightful incomes.

Ten years after the finding of collusion, Garvey’s individual claim proceeding was conducted. Smith was the key witness on behalf of Garvey. 7 In spite of his determination in the earlier arbitration that the testimony of the owners (including Smith) had been false, and in spite of the fact that the owners’ testimony had been deliberately. designed to cover-up their invidious scheme, the arbitrator rejected Garvey’s claim on the ground that Smith’s 1986 testimony had, in effect, been truthful. In doing so, the arbitrator first grudgingly acknowledged that, “taken on its face, [Smith’s 1996 letter] appears to support the position of Garvey advanced in this proceeding.” In fact, the letter does far more than appear to support Garvey’s position. It unequivocally endorses Garvey’s testimony in every respect: the letter states explicitly that Smith made Garvey an offer before the end of the 1985 season — an offer that the letter states was subsequently withdrawn “due to the collusion among the clubs.” After making his grudging half-way concession regarding the contents of Smith’s 1996 letter, the arbitrator proceeded to quote extensively from the statements made by Smith during the 1986 collusion hearings. These statements had, of course, been made for the sole purpose of supporting the owners’ attempt to deceive the arbitrators — an attempt that the arbitration panel had squarely rejected. Nevertheless, because of “stark contradictions between the contents of the recently produced letter from Smith and his earlier sworn testimony that the Padres were not interested in re-signing Garyey,” the arbitrator proceeded to reject Smith’s confession of collusion as false and to accept his earlier denials of collusion as true;

Under ordinary circumstances, we would accept a conclusion by the arbitrator that Smith told the truth in his 1986 testimony and lied in his 1996 letter even if that conclusion were clearly erroneous. See Sheet Metal Workers v. Arizona Mechanical & Stainless, Inc., 863 F.2d 647 , 653 (9th Cir.1988). We are presented, however, with the extraordinary circumstance in which the arbitrator’s own rulings make clear that, more than being simply erroneous, his finding is completely inexplicable and borders on the irrational. In this circumstance, given the arbitrator’s professional experience, the decision can be explained only by his desire to dispense his *591 own brand of industrial justice. No other plausible explanation exists.

As the earlier discussion of the collusion proceedings explains, the panel of arbitrators headed by Arbitrator Roberts had previously ruled that the 1986 testimony by the owners, including Smith, was untruthful. The owners’ testimony during those hearings had been designed for the sole purpose of convincing the arbitrators that no collusion had taken place, and the arbitrators had concluded that the owners’ testimony was not true. In light of that conclusion, Arbitrator Roberts’ determination in Garvey’s individual claim proceeding that Smith’s (false) 1986 collusion testimony somehow precluded the crediting of his (truthful) confession in 1996 is, to say the least, bizarre.

The owners’ mendacity in their 1980’s collusive efforts to depress the ballplayers’ income was in many ways as damaging to baseball as the Black Sox scandal of 1919. 8 The scope of the owners’ deceit and fabrications in their 1980’s effort to cheat their employees out of their rightful wages was wholly unprecedented, as was the financial injury suffered by the ballplayers. That the arbitrator would in these circumstances rely on Smith’s statements made in the collusion hearing, and on the basis of those false statements reject Smith’s later effort to remedy the injury he had caused, surpasses understanding. The only inference that can fairly be drawn from the arbitrator’s current crediting of Smith’s earlier perjurious testimony is that ble arbitrator was attempting to “dispense bis own brand of industrial justice.” For this reason, we decline to enforce his award.

We emphasize that the dispositive determination in this case is without any question the arbitrator’s rejection of Smith’s “testimony” on the ground that it conflicted with his earlier testimony on behalf of the owners. At the later hearing, Smith’s and Garvey’s descriptions of the events that occurred were entirely consistent: both agreed that an extension offer had been made and subsequently withdrawn. While the arbitrator purported to rely on the lack of credibility of “the Smith testimony,” “coupled with the absence of any other corroboration ... submitted by Garvey,” the lack of “other” corroboration simply bolstered, in the arbitrator’s view, his previously made decision not to credit Smith’s testimony. It therefore adds nothing to that decision. Moreover, the record fully explains why Smith’s evidence was the only direct evidence corroborating Garvey’s testimony. Garvey’s agent submitted evidence that Garvey and Smith negotiated directly regarding the extension, without any third-party assistance. The arbitrator simply disregarded the record when he added his “absence of corroboration” assertion.

We should also stress that while the falsity of Smith’s 1986 testimony is readily apparent from the outcome of the collusion hearing, the truthfulness of Smith’s state- *592 merits in Garvey’s individual claim proceeding finds strong support in Smith’s explanation of his reasons for coming forward when asked by the parties. In explaining the contradictions with his earlier testimony, Smith confessed that some parts of his 1986 testimony had been untrue, and that other parts had been “a little cute” — all in an effort to avoid acknowledging that he had made an offer to Garvey. He then went on to say that he felt compelled to offer evidence now “because he was trying to right what [he] fe[lt] was a wrong [he] participated in against [Garvey].” Finally, Smith noted that he had no relationship of any kind with Garvey for the past seven or eight years, and that his only baseball-related relationships during that period were with other baseball owners. No one has suggested that Smith had any motive to lie at the current hearing.

The unique character of the proceeding at issue in the present case may explain in part, if any explanation is possible, why Arbitrator Roberts dispensed his “own brand of industrial justice.” In ordinary labor disputes, arbitrators have many institutional advantages that help ensure the legitimacy of labor arbitration awards. Garvey’s proceeding, however, bears little resemblance to the proceedings customarily employed to resolve labor disputes. It lacked two important institutional safeguards present in the ordinary arbitral proceeding: the perspective provided by the adversarial process, and the guidance provided by an established law of the shop. By providing a reliable- mechanism for finding facts and examining the strengths and weaknesses of conflicting arguments, the adversarial process, informal though it may be in the arbitration context, helps ensure that arbitral conclusions are sound. The present arbitration was unusual in that no such process existed: neither the baseball owners nor the Players’ Association had a vested interest in whether a particular player received a portion of the fixed settlement fund. Similarly, there was no collective bargaining agreement to construe and no well-established law of the shop to help fill in the interstices. Instead, there was only a one time “Framework” for the arbitrator to implement.

While we set aside the award in this case, we consider the circumstances unique. We doubt that our decision will have any precedential value in cases involving more traditional methods of resolving disputes in the workplace. Certainly, we are aware of few, if any, cases in which arbitrators have dispensed their own brand of industrial justice in the ordinary arbitral process, or indeed in any proceeding. That such occurred here is regrettable, but fortunately not beyond repair.

III. CONCLUSION

Based on the foregoing, the district court’s denial of Garvey’s Amended Motion to Vacate Arbitration Award is reversed.

REVERSED and REMANDED with directions to vacate the award.

. Parts I and II.A were prepared by Judge Whyte, who is the author of the dissenting opinion. Judge Whyte graciously granted the majority permission to adopt these two sections, on which all members of the panel agree.

. It is unclear to the court why the due date for submitting completed claims questionnaires preceded the issuance of the arbitration panel's opinion approving the Framework.

. Arbitrator Thomas T. Roberts has been dismissed as a defendant to this action.

. Our circuit has identified two other exceptions to the general deference to an arbitrator's award: when the arbitrator exceeds the scope of the issues submitted, and when the award runs counter to public policy. See SFIC Properties, Inc., 103 F.3d at 925 .

. We disagree with the dissent's attempt to justify the award on the basis of Garvey’s earlier claims questionnaires, in which he did not indicate that he had been offered a contract extension prior to the period of collusion. Our dissenting colleague apparently believes that the arbitrator could have validly relied on the contents of the claims questionnaires as a basis for concluding that no offer was in fact made. We cannot agree that the arbitrator's decision may be affirmed on that basis: the record contains no indication that the arbitrator relied on the questionnaires, and it would have been improper for him to have done so. First, the arbitrator’s decision makes no mention of the questionnaires, and relies instead on the statements made by Ballard Smith at the 1986 collusion hearing. Second, the arbitrator could not properly have relied on the claims questionnaires, because the arbitrator himself had previously established a procedure governing the hearings under which the questionnaires could not be considered. In setting forth the rules to be applied to his evaluation of players' claims, the arbitrator held that he would "treat[ ] those claims of the objecting players advanced in writing and/or at oral argument as definitive of their position rather than potentially conflicting claims they may have advanced earlier in [the claim resolution] procedure.” In response to a question from Garvey’s counsel during Garvey's hearing, the arbitrator made it clear that under this previously established policy he would not consider "conflicting positions which might have been taken earlier, such as in the claims questionnaires.” Garvey's counsel was entitled to rely on this representation, and indeed appears to have done so.

. The claim procedure was very informal. Smith's evidence was provided by letter and telephone call, the latter being reported in a communication from the Players’ Association. Yet, Smith's evidence was afforded the same dignity as other evidence provided in person.

. It is interesting to note that many historians believe that the Black Sox scandal was itself the product of the economic exploitation of baseball players by a baseball club owner. The 1919 White Sox (known after the scandal as the Black Sox) were the best team in baseball that year, but the team was also one of the worst paid. The then-nonunionized players’ salaries were so low because the players had been forced to sign contracts containing a "reserve clause,” which prevented them from changing teams without the permission of the owner. (In effect, these reserve clauses operated in a manner similar to the owners’ collusive practices in the mid-eighties.) In addition to using these exploita-live contracts to depress player salaries, the owner of the team, Charles Comiskey, regularly cheated the players out of other benefits and bonuses. Many think it was this grossly unfair treatment that led the White Sox players, including Shoeless Joe Jackson, to throw the 1919 World Series for money. See Eliot Asinof, Eight Men Out (1962); see also Eight Men Out (Orion 1988). We might note, however, that the situation has changed dramatically in recent years: observers today would find little reason to complain that baseball’s current salary structure is unfair to the players or that it results in inadequate salaries and signing bonuses for its top stars.