Courts, arbitrators and legal scholars have long debated the issue of whether it is appropriate for an arbitrator to consider external law in order to reach a decision in a specific dispute or grievance.

 The primary responsibility of the labor or management advocate is that of persuasion.

 Those who promoted arbitration of labor-management disputes understandably argued that arbitrators would have expertise that judges could hardly be expected to possess.

 For more than a century, unions and employers in the United States have had a stormy relationship.