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    SmartBrief enables case brief popups that define Key Terms, Doctrines, Acts, Statutes, Amendments and Treatises used in this case.

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    Dispute Resolution Keyed to Menkel-Meadow, 3rd Ed.

    Eastern Associated Coal Corp. v. United Mine Workers, District 17

    Citation:

    531 U.S. 57 (2000)

    Facts

    James Smith worked for Eastern Associated Coal Corp. as a member of a road crew, driving heavy vehicles on public highways. As a commercial driver, Smith was subject to Department of Transportation regulations requiring random drug testing. In March 1996, Smith tested positive for marijuana, and Eastern sought to discharge him. The union contested this action through arbitration, and the arbitrator ordered Smith’s reinstatement with conditions including a 30-day suspension, participation in a substance-abuse program, and ongoing drug testing. Between April 1996 and January 1997, Smith passed four random drug tests, but in July 1997, he again tested positive for marijuana. Eastern again sought to discharge Smith, but the arbitrator ordered reinstatement with stricter conditions, including a three-month suspension, payment of arbitration costs, continued substance-abuse treatment, continued drug testing, and a signed resignation letter that would take effect if Smith tested positive again within five years. The arbitrator cited Smith’s 17-year good employment record and personal circumstances as mitigating factors. Eastern challenged the award in federal court, arguing it violated public policy against allowing drug users to operate dangerous machinery.

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    Eastern Associated Coal Corp. v. United Mine Workers, District 17