In Major League Baseball Players Association v. Garvey, the United States Supreme Court affirmed an arbitrator’s decision to deny a former major league baseball player recovery from a settlement fund established to compensate players who were damaged by collusion amongst team owners in the market for free agent baseball players. In so doing, the Supreme Court reversed the United States Court of Appeals for the Ninth Circuit and reaffirmed the principle the Court announced in United Steelworkers v. Enterprise Wheel & Car Corp., that judicial review of an arbitrator’s decision in the labor context is extremely limited. The Supreme Court’s holding was correct and logical application of the United Steelworkers principle to the facts of the Garvey case.

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