Judicial Deference to Arbitrators' Decisions
In Pennsylvania Liquor Control Board v. Independent State Stores Union, 520 Pa. 266, 553 A.2d 948 (1989), the Pennsylvania Supreme Court identified an important caveat to the concept of judicial deference to the decisions of arbitrators:
An arbitrator is confined to interpretation and application of the collective bargaining agreement; he does not sit to dispense his own brand of industrial justice.
He may of course look for guidance from many sources, yet his award is legitimate only so long as it draws its essence from the collective bargaining agreement.
When the arbitrator's words manifest an infidelity to this obligation, courts have no choice but to refuse enforcement of the award (emphasis added). Id. at 273, 553 A.2d at 951 (citing United States Steelworkers of America v. Enterprise Wheel and Car Corp., 363 U.S. 593, 597, 4 L. Ed. 2d 1424, 80 S. Ct. 1358 (1960)).