Miller Brewing Co. v. Brewery Workers Local Union No. 9

How later courts describe this case

• holding that section 301 supersedes the Arbitration Act because section 301 was enacted long after the Arbitration Act and deals specifically, as the Arbitration Act does not, with labor contracts
• court may reverse award that “clearly” was not “within the contemplation of the parties and ... implicitly authorized by the agreement”
• general rule is that an employee may not move to vacate arbitration award unless the union has breached its duty of fair representation
• FAA’s exclusion of contracts of employment of workers engaged in interstate commerce limited to workers employed in transportation industries
• suppression not required for technical violations of wiretap statute in absence of bad faith
• Section 1 exclusion limited to workers employed in the transportation industry.
• exclusionary language limited to workers employed in the transportation industries