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American Postal Workers Union, AFL-CIO v. United States Postal Serv.

United States Court of Appeals, Second Circuit

June 6, 2014

AMERICAN POSTAL WORKERS UNION, AFL-CIO, Plaintiff-Appellee,
v.
UNITED STATES POSTAL SERVICE, Defendant-Appellant

Argued May 19, 2014.

Appeal from the United States District Court for the Southern District of New York. No. 12 Civ. 7896 (KBF) -- Katherine B. Forrest, Judge.

Defendant United States Postal Service appeals from the May 16, 2013 judgment of the United States District Court for the Southern District of New York (Katherine B. Forrest, Judge) granting the motion of plaintiff American Postal Workers Union (" APWU" ) to vacate an arbitral award on the basis that the arbitrator exceeded his powers under the relevant agreement by applying the doctrine of collateral estoppel against APWU. We hold that the arbitrator's decision to apply collateral estoppel--which was based on his interpretation of particular provisions of the arbitration agreement, and is within an arbitrator's authority to decide under a broad arbitration agreement--did not exceed his powers under the arbitration agreement as would be required to justify vacating the award.

SARAH T. KANTER (Darryl J. Anderson, on the brief), O'Donnell, Schwartz & Anderson, P.C., Washington, DC, for Plaintiff-Appellee American Postal Workers Union, AFL-CIO.

MICHAEL J. BYARS (Emily E. Daughtry, on the brief), Assistant United States Attorneys, for Preet Bharara, United States Attorney for the Southern District of New York, New York, NY, for Defendant-Appellant United States Postal Service.

Before: WINTER, WALKER and CABRANES, Circuit Judges.

OPINION

Page 110

José A. Cabranes, Circuit Judge :

Defendant United States Postal Service (" USPS" ) appeals from the May 16, 2013 judgment of the United States District Court for the Southern District of New York (Katherine B. Forrest, Judge ) granting the motion of plaintiff American Postal Workers Union (" APWU" ) to vacate an arbitral award on the basis that the arbitrator had exceeded his powers under the relevant agreement by applying the doctrine of collateral estoppel against APWU.[1]

We hold that the arbitrator's decision to apply collateral estoppel--which was based on his interpretation of particular provisions of the arbitration agreement, and is within an arbitrator's authority to decide under a broad arbitration agreement--did not exceed his powers under the arbitration agreement as would be required to justify vacating the award.

Accordingly, we reverse the May 16, 2013 judgment of the District Court and remand with instructions to confirm the arbitral award.

BACKGROUND

Carla LaGreca, a former USPS employee, was initially employed as a Mail Processing Clerk. Around 1986, she applied for workers' compensation benefits for carpal tunnel syndrome developed in connection with her job. In 2007, the USPS reassigned LaGreca to a limited-duty position consistent with her work restrictions. In September 2008 the USPS concluded that it no longer had work available consistent with LaGreca's ...


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