Int'l Union, United Auto., Aerospace & Agric. Implement Workers Of Am. v. United Farm Tools, Inc., 762 F.2d 76 (8th Cir. 1985). · Go Syfert
Int'l Union, United Auto., Aerospace & Agric. Implement Workers Of Am. v. United Farm Tools, Inc., 762 F.2d 76 (8th Cir. 1985). Cases Citing This Book View Copy Cite
30 citation events (14 in the last 25 years) across 9 distinct courts.
Strongest positive: Glass-Inspiration GMBH Design + Engineering v. M.G. McGrath, Inc. Glass & Glazing (mnd, 2025-01-27)
Treatment trajectory · 1985 → 2026 · click a year to view as-of
1985 2005 2026
Top citers, strongest first. 16 distinct citers. How cited ↗
cited Cited as authority (rule) Glass-Inspiration GMBH Design + Engineering v. M.G. McGrath, Inc. Glass & Glazing
D. Minnesota · 2025 · confidence medium
In that case, the Eighth Circuit affirmed an award of attorneys’ fees against a party that refused to honor an arbitration award. 762 F.2d at 77.
cited Cited as authority (rule) Procter & Gamble Manufacturing Company, The v. Association of Employees of the St. Louis Plant
E.D. Mo. · 2019 · confidence medium
Div., 762 F.2d 76, 77 (8th Cir.1985).
cited Cited as authority (rule) Astanza Design, LLC v. Giemme Stile, S.p.A.
M.D.N.C. · 2016 · confidence medium
Div., 762 F.2d 76, 77 (8th Cir. 1985) (per curiam) (holding that an unjustified refusal to abide by an arbitrator’s award may constitute bad faith for the purpose of awarding attorneys’ fees); Com.
discussed Cited as authority (rule) Crossville Medical Oncology, P.C. v. Glenwood Systems, LLC (2×) also: Cited "see, e.g."
6th Cir. · 2015 · confidence medium
Div., 762 F.2d 76, 77 (8th Cir.1985) (citing Int’l Union of Petroleum & Indus.
cited Cited as authority (rule) Tower Rock Stone Co. v. Quarry & Allied Workers Local No. 830
E.D. Mo. · 2013 · confidence medium
Div., 762 F.2d 76, 77 (8th Cir.1985).
cited Cited as authority (rule) Laidlaw Transit v. Inter National Broth. of Teams.
E.D. Mo. · 2006 · confidence medium
Implement Workers of America v. United Farm Tools, Inc., 762 F.2d 76, 77 (8th Cir.1985) (citations omitted).
discussed Cited as authority (rule) Industrial Wire Products v. Teamsters Local Union
E.D. Mo. · 2002 · confidence medium
Attorneys' Fees Although the statute here does not explicitly authorize an award of attorneys' fees, the Eighth Circuit Court of Appeals has held that fees can be awarded where a party has "acted in bad faith, vexatiously, wantonly, or for oppressive reasons." International Union, United Automobile, Aerospace and Agricultural Implement Workers v. United Farm Tools, Inc., 762 F.2d 76, 77 (8th Cir.1985).
cited Cited as authority (rule) UHC Management Co. v. Computer Sciences Corp.
8th Cir. · 1998 · confidence medium
Div., 762 F.2d 76, 77 (8th Cir.1985) (per curiam).
discussed Cited as authority (rule) INTERNATIONAL ASS'N v. Trans World Airlines
E.D. Mo. · 1998 · confidence medium
IFFA urges the Court to apply the standard of International Union, United Automobile, Aerospace and Agricultural Implement Workers of America v. United Farm Tools, Inc., 762 F.2d 76, 77 (8th Cir.1985), in which the Eighth Circuit held that an "unjustified refusal to abide by an arbitrator's award may constitute bad faith," warranting the imposition of attorney's fees.
discussed Cited as authority (rule) International Brotherhood of Electrical Workers, Local No. 265 v. O.K. Electric Co., Inc., a Nebraska Corporation Quantum Electric, Inc., a Nebraska Corporation and M & B Corporation, a Nebraska Corporation, International Brotherhood of Electrical Workers, Local No. 265 v. O.K. Electric Co., Inc., a Nebraska Corporation, Quantum Electric, Inc., a Nebraska Corporation and M & B Corporation, a Nebraska Corporation
8th Cir. · 1986 · confidence medium
Although an "unjustified refusal to abide by an arbitrator's award may constitute bad faith for the purpose of awarding attorneys' fees," United Automobile, Aerospace & Agricultural Implement Workers Local 1165 v. United Farm Tools, Inc., 762 F.2d 76, 77 (8th Cir.1985) (per curiam), O.K.
discussed Cited as authority (rule) International Brotherhood of Electrical Workers v. O.K. Electric Co.
8th Cir. · 1986 · confidence medium
Although an “unjustified refusal to abide by an arbitrator’s award may constitute bad faith for the purpose of awarding attorneys’ fees,” United Automobile, Aerospace & Agricultural Implement Workers Local 1165 v. United Farm Tools, Inc., 762 F.2d 76, 77 (8th Cir.1985) (per curiam), O.K.
cited Cited as authority (rule) International Association Of Heat And Frost Insulators And Asbestos Workers, Local Union 34, Afl-Cio, Appellee v. General Pipe Covering, Inc.
8th Cir. · 1986 · confidence medium
Division, 762 F.2d 76, 77 (8th Cir.1985), General Pipe's challenge of the award was justified, as shown by the necessity for a remand.
cited Cited as authority (rule) International Ass'n of Heat & Frost Insulators v. General Pipe Covering, Inc.
8th Cir. · 1986 · confidence medium
Division, 762 F.2d 76, 77 (8th Cir.1985), General Pipe's challenge of the award was justified, as shown by the necessity for a remand.
cited Cited "see" Roe v. Cargill, Inc.
W.D. Ark. · 2004 · signal: see · confidence high
See Int’l United v. United Farm Tools, Inc., 762 F.2d 76 , 77 (8th Cir.1985).
cited Cited "see, e.g." United Food and Commercial Workers, Local 400 v. Marval Poultry Company, Incorporated
4th Cir. · 1989 · signal: see also · confidence low
See also UAW v. United Farm Tools, Inc., 762 F.2d 76 , 77 (8th Cir.1985) (awards compelled by an “unjustified refusal to abide by an arbitrator’s award”).
Retrieving the full opinion text from the archive…
International Union, United Automobile, Aerospace and Agricultural Implement Workers of America and Its Local Union No. 1165
v.
United Farm Tools, Inc., Speedy Mfg. Division
84-2154.
Court of Appeals for the Eighth Circuit.
May 16, 1985.
762 F.2d 76
Cited by 12 opinions  |  Published

762 F.2d 76

119 L.R.R.M. (BNA) 2559, 103 Lab.Cas. P 11,480

INTERNATIONAL UNION, UNITED AUTOMOBILE, AEROSPACE AND
AGRICULTURAL IMPLEMENT WORKERS OF AMERICA and its
Local Union No. 1165, Appellees,
v.
UNITED FARM TOOLS, INC., SPEEDY MFG. DIVISION, Appellant.

No. 84-2154.

United States Court of Appeals,
Eighth Circuit.

Submitted April 26, 1985.
Decided May 16, 1985.

Marshall G. Hardesty, Jr., Cedar Rapids, Iowa, for appellant.

M. Jay Whitman, Detroit, Mich., for appellees.

Before ROSS, ARNOLD and BOWMAN, Circuit Judges.

PER CURIAM.

1

United Farm Tools, Inc., Speedy Manufacturing Division (United Farm) appeals the District Court's[1] award of attorneys' fees to the International Union, United Automobile, Aerospace and Agricultural Implement Workers of America, and its Local Union No. 1165 (Union) in the Union's suit to enforce a labor arbitration award against United Farm. United Farm asserts that the District Court erred in awarding attorneys' fees to the Union because the record did not support a finding that United Farm had acted in bad faith. For the reasons stated below, we affirm.

2

Pursuant to a collective bargaining agreement, the Union filed a grievance protesting the contracting out of work performed on United Farm's premises. The grievance was submitted to arbitration. The arbitrator held that United Farm had violated the collective bargaining agreement, and ordered United Farm, inter alia, to reimburse four employees for the overtime lost during the contracting out. After repeated requests from the Union, the Company failed to reimburse these employees. The Union then sued to enforce the arbitration award. The District Court granted a summary judgment in favor of the Union, and also awarded the Union attorneys' fees.

3

United Farm argues that the record before the District Court did not support the finding of bad faith required to support an award of attorneys' fees. United Farm contends that an honest disagreement existed as to the validity of the award because the arbitrator exceeded his authority in making the award. We disagree.

4

A court may "assess attorney fees against a party who has acted in bad faith, vexatiously, wantonly, or for oppressive reasons." Jaquette v. Black Hawk County, Iowa, 710 F.2d 455, 462 (8th Cir.1983). An unjustified refusal to abide by an arbitrator's award may constitute bad faith for the purpose of awarding attorneys' fees. Int'l Union of Petroleum and Industrial Workers v. Western Industrial Maintenance, Inc., 707 F.2d 425, 428 (9th Cir.1983); see also Lackawanna Leather Co. v. United Food and Commercial Workers Int'l Union, 706 F.2d 228, 232 (8th Cir.1983) (en banc).

5

United Farm's contention that the validity of the award was honestly disputed is unconvincing because United Farm did not act to have the award set aside. We agree with the District Court's conclusion that United Farm failed to show any substantial ground justifying its refusal to comply with the arbitrator's award. Because this unjustified refusal to comply with the award constituted evidence of bad faith, the Union was entitled to recover attorneys' fees. Further, we agree with the District Court that the amount of attorneys' fees awarded was reasonable. Accordingly, the judgment of the District Court is affirmed.

1

The Hon. Edward J. McManus, Chief Judge, United States District Court for the Northern District of Iowa