Colfax Envelope Corp v. Local No. 458-3M, Chicago Graphic Communications Intern. Union, AFL-CIO

Facts

Plaintiff hired employees to operate its two printing presses. These employees were represented by Defendant. Previously, Defendant would negotiate a collective-bargaining agreement with the Chicago Lithographers Association (CLA) and send a summary of the terms to Plaintiff for approval. If Plaintiff did not agree with those terms, it had the right to negotiate separately. The collective-bargaining agreement set the minimum manning requirements for each type of printing press. Plaintiff had two presses that were 78 inches wide and, under the existing collective-bargaining agreement, had to be manned by four employees each. When a summary of the newest changes to the agreement was sent to Plaintiff, the summary listed one of the manning requirements as “4C 60 Press-3 Men,” which Plaintiff interpreted as requiring presses 60 inches or wider to be manned by three employees. Finding this advantageous, Plaintiff agreed to the changes in the summary. Upon receiving the final agreement, Plaintiff learned that “4C 60 Press-3 Men” meant three men were required for presses of 60 inches or less. Plaintiff sought a declaration stating that no collective-bargaining agreement was created due to lack of agreement on an essential term. The union sought to compel arbitration because the agreement contained an arbitration clause. The district court ordered arbitration, finding that the contract was enforceable because the disputed term unambiguously referred only to 60-inch presses. Plaintiff appealed.