Occidental Chemical Corp. V. International Chemical Workers Union

This appeal requires us to determine the most appropriate statute of limitations to apply in a case from Michigan, brought pursuant to § 301 of the Labor 2 Occidental v. International No. 87-1728 Management Relations Act of 1947 (LMRA) to vacate an arbitration award. The employer filed this action approximately five months after the arbitrator released his opinion and award. The district court applied the three-month limitations period found in § 12 of the United States Arbitration Act (USAA) and dismissed the suit as untimely.