Pittsburgh Mailers Union Local 22 v. PG Publishing Co.

The Third Circuit overruled its decision in Luden’s Inc. v. Local Union No. 6 of the Bakery, Confectionery & Tobacco Workers International Union in light of two intervening United States Supreme Court Cases: M & G Polymers USA, LLC v. Tackett and CNH Industrial N.V. v. Reese. At issue was an arbitration provision in a collective bargaining agreement (CBA). The Third Circuit determined that a provision in the CBA did not survive the CBA’s expiration and remain effective for an extended period during which the parties attempted to negotiate a new CBA. The Court ruled that the contract provisions were clear and that the arbitration obligation lasted only as long as the CBA.

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