Unite Here International Union v. Wilton Rancheria

── Unite Here International Union v. Wilton Rancheria ── Court: Court of Appeals for the Ninth Circuit Date: April 08, 2026 Category: General NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS APR 8 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT UNITE HERE INTERNATIONAL No. 25-234 UNION, D.C. No. 2:23-cv-02767-KJM-SCR Plaintiff - Appellee, v. MEMORANDUM* WILTON RANCHERIA, Defendant - Appellant. Appeal from the United States District Court for the Eastern District of California Kimberly J. Mueller, District Judge, Presiding Argued and Submitted December 4, 2025 San Francisco, California Before: R. NELSON, COLLINS, and VANDYKE, Circuit Judges. Defendant-Appellant Wilton Rancheria (“the Tribe”) appeals the district court’s denial of the Tribe’s motion to vacate an arbitration award directing the Tribe to cooperate with UNITE HERE’s (“the Union”) attempts to use the procedure for electing a collective bargaining representative established by the parties’ 2017 * This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. Memorandum of Agreement (“MOA”). We have jurisdiction under 28 U.S.C. § 1291; the district court had jurisdiction over the Union’s initial complaint under 28 U.S.C. § 1331 and over the Tribe’s motion to vacate under 28 U.S.C. § 1367. When a district court denies a motion to vacate an arbitration award, we review the district court’s denial de novo. ASARCO LLC v. United Steel, Paper & Forestry, Rubber, Mfg., Energy, Allied Indus. & Serv. Workers Int’l Union, AFL-CIO, CLC, 910 F.3d 485, 489 (9th Cir. 2018). Under the Federal Arbitration Act, federal courts review an arbitration award very deferentially, upholding it “unless it is completely irrational or it constitutes a manifest disregard of the law.” G.C. & K.B. Invs., Inc. v. Wilson, 326 F.3d 1096, 1105 (9th Cir. 2003) (quoting French v. Merrill Lynch, Pierce, Fenner & Smith, Inc., 784 F.2d 902, 906 (9th Cir. 1986)). Failures to “understand or apply the law”—even “misinterpretations of law”—do not satisfy this standard. French, 784 F.2d at 906 (quoting Am. Postal Workers Union AFL- CIO v. U.S. Postal Serv., 682 F.2d 1280, 1285 (9th Cir. 1982)). The district court properly denied the Tribe’s motion to vacate. There is no question that the parties authorized the arbitrator to decide whether the Union had to use the election procedure described in the Tribal Labor Relations Ordinance (“TLRO”), or whether the Tribe had to comply with the Union’s efforts to use the MOA election procedure. The arbitrator focused his analysis on that “essential dispute,” noting that “compliance with the MOA does not affect compliance” with 2 25-234 other TLRO provisions. Then, exercising the authority granted to him by the parties, the arbitrator rejected as “unconvincing” and “implausible” the Tribe’s argument that the MOA language incorporating the same TLRO the Tribe would formally enact in 2019 “mean[s] the Union agreed that it must follow the election procedure in the TLRO because that procedure is exclusive.” The arbitrator noted that similar TLROs had never been interpreted to “vitiate[]” the election procedure prescribed by similar MOAs, and that reading the TLRO procedure as the exclusive election method would turn the MOA provisions describing the alternative procedure into surplusage. The Tribe fails to persuasively argue that this ground of the arb