In a recent decision, the Second Circuit Court of Appeals vacated a lower court ruling that had denied a unionโs attempt to compel arbitration with Xerox Corporation. The dispute arose after Xerox allegedly altered health benefits for retirees, prompting the union to file a grievance under an expired collective bargaining agreement.
The district court had previously dismissed the union’s claim, reasoning that the agreement had expired and no longer applied. However, the Second Circuit disagreed, emphasizing that certain provisions in the agreement could reasonably be interpreted as extending beyond its expirationโespecially those tied to retiree benefits or deferred compensation.
Importantly, the appellate court held that the issue of whether these terms are enforceable through arbitration should be decided by an arbitrator, not the court. The case has been sent back for further proceedings to determine arbitrability.
This ruling reinforces the Second Circuitโs strong pro-arbitration stance and signals that parties should expect to honor arbitration clauses, even after contract expiration, if the language supports such intent.
