“3rd Circuit Issues Precedential Opinion in Verizon Labor Arbitration Award Dispute”

Law/Street has this article, discussing the Third Circuit’s decision in Verizon Pennsylvania, LLC v. Communicatins Workers of America, AFL-CIO, Local 13000, in which the court reaffirmed the ongoing vitality of the functus officio doctrine: “we hold that it is alive and well in this Court.” Under the doctrine, as the article explains, “once an arbitrator, unlike a judge, issues a finding she may not modify it absent all parties’ consent.”

In the case before it, a union arbitration board determined that Verizon violated a collective bargaining agreement by arranging to have cable boxes shipped to customers rather than delivered by union technicians. The arbitrators went astray, however, when they subsequently expanded the scope of their award.

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