The employees of Robinson Ford Sales, a local auto dealer, are represented by Local 303 of the United Automobile Workers Union. Because of slumping sales, the dealership announces that it must change the medical insurance provided to the employees under the collective agreement by doubling the copays and deductibles that the employees are required to pay. The union objects that the change violates the collective agreement, and demands that the dealership submit the dispute to arbitration under the collective agreement arbitrations procedures.

The dealership refuses to do so, and the union files suit under Section 301 of the NLRA to force the employer to submit the dispute to arbitration. The trial court refuses to order Robinson to arbitrate the dispute, holding that Robinson’s reduced business was a legitimate reason for making the changes. The union then appeals to the federal court of appeals.

Should the court of appeals order the employer to arbitrate the dispute? What factors should the court consider when deciding whether to order arbitration?