Stafford v. Greater Cleveland Regional Transit Auth

In Stafford v. Greater Cleveland Regional Transit Auth. (Dec. 23, 1993), Cuyahoga App. No. 63663, 1993 Ohio App, the Eighth District Court of Appeals stated: The issue raised by Stafford's first and ninth assignments of error is whether the trial court erred in denying his motion to vacate the arbitration award. In his first assignment of error, Stafford argues that the trial court erred in finding that he lacked standing to challenge the arbitration award. RTA argues that, under R.C. 2711.10, only parties to the arbitration may seek to vacate the award. RTA claims that since Stafford was not a party to the arbitration, he was not authorized to seek to vacate the award. The arbitration committee report lists the parties involved as RTA and Union Local 268. Stafford, as an individual, was not a party to the arbitration. The United States Supreme Court has said that the collective bargaining system subordinates the interests of the individual employee to the collective interests of all employees in the bargaining unit. Hines at 564. In the arbitration process, Stafford was represented by Local 268. The success of the collective bargaining process depends upon the exclusivity of the union's right to represent all employees within its bargaining unit. United Transp. Union, Local 74 v. Consolidated Rail Corp. (1989), 494 U.S. 1051, 110 S. Ct. 1517, 108 L. Ed. 2d 757. The establishment of the union as representative necessarily deprives individual employees of the ability to bargain individually. Id. This court has held that an individual employee lacks standing to vacate an arbitration award to which his union was a party. See Coleman v. Cleveland City School District (September 4, 1992), Cuyahoga App. No. 62570, 1992 Ohio App, unreported. We see no reason to depart from our holding in Coleman. Since Stafford was not a party to the arbitration award, the trial court did not err in finding that he lacked standing to vacate the award. Stafford's first assignment of error is without merit. Id.