Alexander v. Gardner-Denver and Deferral to Labor Arbitration

In Alexander v. Gardner-Denver Co., the Supreme Court held that an employee was entitled to a trial de novo on a Title VII discrimination claim which also had been submitted to final and binding labor arbitration. The note analyzes the Alexander decision after first surveying the history and extent of deferral to labor arbitration by the NLRB and the courts. The conclusion is reached that Alexander is best viewed as a Title VII case defining Title VII rights, and that the Alexander decision does not represent a rejection of the national labor policy favoring the arbitration of labor disputes