United Food & Commercial Workers Union v. Seneca Foods Corporation

Background

The Union represents approximately 166 employees at Seneca’s Rochester, Minnesota facility. The parties’ collective bargaining agreement covered the period from February 1, 2024 through February 1, 2028, and incorporated Seneca’s paid-time-off policy for Minnesota employees.

The dispute concerned employees who were scheduled for mandatory overtime shifts longer than eight hours but missed work for a qualifying sick or safe-time reason. The Union interpreted the 2024 paid-time-off policy to require use of no more than eight hours of paid time off. Seneca interpreted the policy to require employees to use enough paid time off to cover the entire scheduled shift.

The Union filed a grievance, and the parties submitted the dispute to arbitration. On March 1, 2025, the Arbitrator issued an award providing that the parties’ competing interpretations would be applied alternately to disputed absences occurring on or after April 29, 2024. Seneca did not file a motion to vacate or modify the award within 90 days.

Seneca later adopted a new paid-time-off policy that became effective January 1, 2025. The new policy stated that employees using sick or personal paid time off had to use enough time to cover their actual shift or workday. The Union did not file a grievance challenging Seneca’s authority to adopt that policy or challenging its contents.

Confirmation of the Arbitration Award

The court held that the arbitration award resolved the parties’ dispute about the meaning of the 2024 paid-time-off policy. Seneca’s arguments that the Arbitrator had failed to decide the dispute or had improperly relied on his own notions of fairness were challenges that Seneca could have raised in a timely motion to vacate or modify.

Because Seneca did not file such a motion, the court held that Seneca could not later use its counterclaim to challenge the award’s validity. The court therefore granted the Union’s summary-judgment motion to the extent it sought confirmation of the award and denied Seneca’s motion to the extent it sought a declaration that no valid award existed.

Effect of the 2025 Policy

The court separately held that the Arbitrator had not been asked to decide whether the award would continue to apply after Seneca adopted the 2025 policy. The 2025 policy was announced after the arbitration hearing, was not mentioned in the award, and was not the subject of a grievance submitted to the Arbitrator.

The court determined that the collective bargaining agreement gave Seneca the right to change the paid-time-off policy, subject to the stated contractual limitation concerning employees in Minnesota. The court also determined that the Union’s failure to file a timely grievance challenging the 2025 policy prevented the Union from contesting its application in this case. The court granted Seneca’s motion for summary judgment on its second counterclaim and declared that the arbitration award had no application after December 31, 2024.

Attorney Fees and Disposition

The court found that neither side acted unreasonably, frivolously, or in bad faith. It therefore denied both parties’ requests for attorney fees.

The Union’s motion for summary judgment was GRANTED IN PART and DENIED IN PART: the award was confirmed; Seneca’s first counterclaim was DISMISSED WITH PREJUDICE; the Union’s request to have the award apply beyond December 31, 2024 was denied; and the Union’s fee request was denied.

Seneca’s motion for summary judgment was also GRANTED IN PART and DENIED IN PART: its request for a declaration that the award was invalid was denied; its second counterclaim was granted; the court declared that the award had no application after December 31, 2024; and Seneca’s fee request was denied. The opinion’s introductory discussion and one later passage refer to December 2025, but the numbered order expressly uses December 31, 2024.