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Contracts Keyed to Farnsworth
Colfax Envelope Corp. v. Local No. 458-3M
Citation:
20 F.3d 750Facts
Colfax Envelope Corporation (“Colfax”) (plaintiff) did not participate in collective bargaining negotiations with Local No. 458-3M (“Local”) (defendant) and the Chicago Lithographers Association (“CLA”), an association for collective bargaining. Instead, CLA and Local would enter into a collective bargaining agreement together. When it did so, Local would send Colfax a summary of changes that the new agreement made to the old one. When Colfax was satisfied with the changes, Local would send them a copy of the complete new agreement to be signed and returned. In 1991, Local negotiated an agreement with CLA and sent a summary of the changes to Colfax. Believing the summary’s term “4C 60 Press-3 Men” meant four-color presses that printed sheets 60 inches and over that could be manned by three employees, Colfax signed the summary. Colfax had misunderstood the terms of the summary, and later found out the changes were not actually advantageous. Local believed the term meant four-color presses that printed sheets 60 inches and under could be manned by three employees. Colfax brought suit against Local, seeking a declaration that it had no collective bargaining agreement because the parties never agreed to the manning requirements for the printing presses. Local counterclaimed, arguing Colfax had accepted the new agreement and that the agreement mandated arbitration.
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