Labor & Employment Law Daily Wrap Up, LABOR—ARBITRATION—6th Cir.: Company must comply with arbitration award despite not being named in caption, (Dec 2, 2025)

By Molly Platnick

Because the company was on notice of the proceedings and failed to object, it was bound by the arbitration award.

The Sixth Circuit affirmed a district court’s decision enforcing an arbitration award in a case brought by a decommissioning company against a union representing an employee who was dismissed after being approved for long-term disability. The company alleged it was not bound by the arbitration award because its parent company was erroneously named in the arbitration demand’s caption. The company’s attorneys participated in the arbitration and did not raise objections to the award until after it was issued. The court acknowledged the mistake but concluded that it was immaterial and curable because the award on the whole and surrounding context clearly identified the smaller company (Holtec International Corp. v. Michigan State Utilities Workers Council, No. 25-1469 (6th Cir. Nov. 24, 2025)).

The former employee worked full-time for the decommissioning company and was a member of the Michigan State Utility Workers Council, which represented staff before and after the decommissioning company took over the plant. The employee’s role was reduced in September 2022, when he was put on short-term disability due to a medical condition. In March 2023, he was approved for long-term disability, and the company terminated his employment.

Grievance. The union filed a grievance on the employee’s behalf, claiming the terms of the collective bargaining agreement barred the company from firing him and required it to provide benefits for two years. The company disputed the terms of the CBA and the union filed for arbitration.

In April 2024, the arbiter found in favor of the union and ordered the employee reinstated with benefits for two years. The union’s original arbitration demand erroneously named the decommissioning company’s international corporate parent as the respondent. However, counsel for the decommissioning company participated in the arbitration process and, in January 2024, explicitly told the arbitrator he appeared on their behalf. The parties agreed there were “no…procedural questions which would preclude a decision.”

Based on the union’s mistake when filing, in the caption, the arbitrator’s award listed the parent company as the respondent employer. The arbiter retained jurisdiction for 90 days, should there be “any issues that arise between the parties…regarding the implementation” of the award. The parent company refused to implement the arbiter’s decision.

Lower court proceedings. The decommissioning company filed the instant action under the Labor Management Relations Act, asserting the award was invalid and must be vacated because it incorrectly named the international parent company. The district court granted summary judgment for the union, finding that although there was a procedural defect, the “record is replete with evidence [the decommissioning company]…engaged in and intended to be bound by the proceedings.” The decommissioning company timely appealed the lower court’s decision.

Binding effect of the arbiter’s award. The decommissioning company argued it was not bound by the arbiter’s award because only the parent company was named in the caption. The court was unpersuaded, concluding that, taken as a whole, the award could only refer to the decommissioning company. Sixth Circuit case law requires courts to “examine the award and opinion as a whole and attempt to ascertain their unambiguous meaning.” Here, the “recitation of facts” named the decommissioning company as the relevant employer 10 times and quoted language from the CBA between the union and the company. The court found the context “surrounding” the award reinforced it was meant to apply to the decommissioning company: the misnomer was “simply a carryover” from the demand and attorneys for that company, not the parent, appeared at the arbitration. The court describes it as “not credible” to suggest the arbitration intended to bind the parent company, which did not appear and was not a party to the CBA.

Failure to raise objections before the arbitrator. Even if the mistake in the caption was a defect in the proceedings, the decommissioning company waived any objections because it did not object until after the arbiter issued the award. Sixth Circuit case law holds “defects in proceedings prior to or during arbitration may be waived by a party’s acquiescence in the arbitration with knowledge of the defect.” The court interpreted this to mean “an objection is waived whenever there is actual notice of the relief the arbitrator might award.”

In this case, the court found the decommissioning company had actual notice because the parent company was incorrectly listed as the respondent in the initial filing. Instead of objecting, the company continued to appear and explicitly agreed there were no “procedural questions which would preclude a decision.” The court noted the arbiter also gave the company 90 days to object after the award.

Curable misnomer. The court disagreed with the decommissioning company that the doctrine of misnomer did not apply to this case. Contract law stipulates “misnomer of a person or corporation in a written instrument will not defeat a recovery thereon if the identity sufficiently appears from the name employed in the writing or is satisfactorily established by proof.” The court applied this reasoning to judicial proceedings and acknowledged courts have “readily extended this logic…to the arbitration context.” The court likened the instant case to Cigna v. Hudleston, in which the Fifth Circuit held “the arbitration award technically identified the wrong party…[but] everyone involved in the action…knew of and could identify the entity being sued.” Here, the decommissioning company confirmed it understood it was a party to the arbitration when it sent its own attorneys and denied any procedural issues.

The case is No. 1:24-cv-00685.

Judge: Moore, J.

Attorneys: Aaron D. Lindstrom (Barnes & Thornburg) for Holtec International Corp. and Holtec Decommissioning International, LLC. George Harold Kruszewski (Watkins, Pawlick, Calati & Prifti) for Michigan State Utility Workers Council.

Companies: Holtec International Corp.; Holtec Decommissioning International, LLC; Michigan State Utility Workers Council; MSUWC

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