Nolde Bros. Inc. v. Bakery Workers

In Nolde Bros. Inc. v. Bakery Workers (1977) 430 U.S. 243, after termination of its contract, the union sought to compel the employer to arbitrate a dispute over the meaning of the "severance pay" clause in the agreement. The court held that parties to a collective bargaining agreement may agree that rights accrued during the term of the agreement shall be realized after its expiration. ( Id., at p. 249.) "The dispute therefore, although arising after the expiration of the collective-bargaining contract, clearly arises under that contract." ( Id., at p. 249.)