SJC to Judges - Unchallenged Arbitration Awards "shall" be entered as Court Judgments

In the recent 2024 case Boston Teachers Union Local 66 v School Committee of the City of Boston

PARTIES AND FACTS

In a labor union case, an arbitrator ordered the City to hire 18 substitute paraprofessionals.

Claiming that the City had not complied, the Union filed a grievance with the arbitrator who again made an award ordering the hiring. The City did not seek to vacate or modify the arbitrator’s award. The Union sued in Court 19 months later to confirm the Arbitrator’s award and moved for entry of Judgment.

ISSUE

What must a Court do, when asked to Confirm an Arbitrator’s award and enter Judgment on it?

RULING

Enter Judgment and enforce the Arbitration award.

REASONS

For labor disputes, a Statute states that the Court “shall” confirm an arbitration award at the request of a party (unless there was a timely motion to vacate or modify the award – which in this case there was not).

There are limited grounds to challenge an arbitration award (fraud, payoffs) but if you don’t mount the challenge in time, the award can  be entered in Court as a Judgment.

There is a strong public policy interest of Massachusetts in promoting arbitration as a means of dispute resolution.

As long as there has been no timely request for vacating or modifying the Arbitration award, upon application for confirmation of the award, the Superior Court “shall” confirm it and enter Judgment.