Citgo Asphalt Refining Co. v. The Paper, Allied-Industrial Chemical, and Energy Workers Intl. Union Local No. 2-991

A Third Circuit panel reversed the District Court’s confirmation of a labor arbitrator’s decision that CITGO’s zero tolerance drug abuse policy was unreasonable because it did not offer a second chance or rehabilitation opportunities to an employee who tested positive on a random drug test. The district panel found that the arbitrator’s decision did not draw its essence from the collective bargaining agreement, nor was the zero tolerance policy was reasonable or supported by the record.