HOLTEC INTERNATIONAL CORPORATION and HOLTEC DECOMMISSIONING INTERNATIONAL, LLC, Delaware corporations v. MICHIGAN STATE UTILITY WORKERS COUNCIL (MSUWC) - Articles

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HOLTEC INTERNATIONAL CORPORATION and HOLTEC DECOMMISSIONING INTERNATIONAL, LLC, Delaware corporations v. MICHIGAN STATE UTILITY WORKERS COUNCIL (MSUWC)

Posted by: Azya Thornton on Nov 24, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ON BRIEF: Aaron D. Lindstrom, BARNES & THORNBURG LLP, Grand Rapids, Michigan, for Appellants.

Attorneys 2: ON BRIEF: George H. Kruszewski, WATKINS, PAWLICK, CALATI & PRIFTI, PC, Madison Heights, Michigan, for Appellee.

Judge(s): MOORE, THAPAR, and RITZ, Circuit Judges

Court Appealed: United States District Court for the Western District of Michigan at Grand Rapids

KAREN NELSON MOORE, Circuit Judge. Holtec Decommissioning International, LLC (“HDI”) and the Michigan State Utility Workers Council (“the Union”) were parties to a collective bargaining agreement. That agreement provided for arbitration of Union members’ grievances. So, when one member disagreed with HDI about his discharge, the Union demanded arbitration on his behalf. Though the demand mistakenly named HDI’s parent company, Holtec International Corporation (“Holtec International”) (collectively with HDI “Holtec” or “Appellants”), with whom there was no agreement, HDI appeared through counsel and participated in the arbitration—that is, until an award was issued in favor of the Union. HDI did not comply with the award, and Holtec filed suit in federal district court seeking vacatur on the ground that the award’s caption mistakenly named Holtec International. The district court declined to vacate the award. This appeal thus turns on a single question: where an arbitration demand and the case’s caption misname the party against whom an award is meant to be entered, but there is no ambiguity as to the real identity of that party, may a federal district court enforce that award? Because it may, we AFFIRM the judgment below.

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