Local Union No. 38, Sheet Metal Workers' International Association, Afl-Cio v. Custom Air Systems, Inc., Quality Air Systems, Inc.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• non-signatory to arbitration agreement could not be bound by arbitration award absent finding by district court that it was the alter ego of a signatory
• “ ‘[A] willing signatory ... seeking to arbitrate with a non-signatory that is unwilling ... must establish at least one of the [following] five theories ... 1
• “Ordinarily, binding a non-signatory to a CBA runs afoul of the fundamental premise that ‘a party cannot be required to submit to arbitration any dispute which he has not agreed to so submit.’”

Source: CourtListener parenthetical corpus (CC0).