Nolde Bros. v. Local No. 358, Bakery & Confectionery Workers Union

In Nolde Bros. v. Local No. 358, Bakery & Confectionery Workers Union (430 U.S. 243) the Supreme Court held that the contractual origin of a grievance arbitration procedure "does not require us to hold that termination of a collective-bargaining agreement automatically extinguishes a party's duty to arbitrate grievances arising under the contract" ( id. at 251). The Supreme Court further noted, under the facts of that case, "there is nothing in the arbitration clause that expressly excludes from its operation a dispute which arises under the contract, but which is based on events that occur after its termination" ( id. at 253). As such, parties were compelled to arbitrate a dispute involving postemployment entitlements arising from a terminated collective bargaining agreement when the events predicating the dispute arose after contract termination.