M. B. Zaninovich, Inc. v. Teamster Farmworker Local Union 946

In M. B. Zaninovich, Inc. v. Teamster Farmworker Local Union 946 (1978) 86 Cal.App.3d 410, although the arbitrator's award failed to include a ruling on how much money was owing to the defendant union, it was also silent regarding the number of employees who had authorized paycheck deductions for union initiation fees and dues, the dates of the authorizations, and the total amount of the deductions. These missing factual findings precluded computation of the amount owing. In addition, the issue submitted for resolution was more specific: " 'How much, if any, is owing by the Company to the Union for such violation or violations of Section 3 of the Agreement?' " (Id. at p. 413.) The Court concluded remand for clarification was inappropriate because the arbitrator had failed to decide a specific issue submitted to arbitration. (Ibid.)