In National Football League Management Council v. National Football League Players Ass’n (Brady),1 the U.S. Court of Appeals for the Second Circuit reversed a judgment of the district court granting the Players Association’s motion to vacate an arbitration award suspending New England Patriots quarterback Tom Brady for four games for participation in a scheme to tamper with game balls during a playoff game. The Second Circuit remanded the case to the district court with instructions to confirm the award. Brady serves as a reminder of the very limited scope of judicial review of arbitration awards.
Brady arose from a disciplinary decision made pursuant to the parties’ collective bargaining agreement and thus was governed by the “extremely limited” framework of judicial review of labor arbitration decisions under Section 301 of the Labor Management Relations Act of 1947 (LMRA).2 The LMRA embodies a federal policy “to promote industrial stabilization through the collective bargaining agreement,” especially through arbitration of grievances.3 The act “reflects a clear preference for the private resolution of labor disputes without government intervention.”4
