The U.S. Court of Appeals for the Sixth Circuit reversed a lower court decision on January 26, 2026, that would have compelled Kellanova to arbitrate employee grievances under an expired collective bargaining agreement at its Grand Rapids, Michigan bakery facility.
In *Bakery, Confectionary, Tobacco Workers and Grain Millers International Union AFL-CIO-CLC, Local No. 70 v. Kellanova* (6th Cir. 2026), Circuit Judge Ritz wrote the opinion reversing the U.S. District Court for the Western District of Michigan's order directing the parties to arbitration.
Kellanova, formerly known as Kellogg Company, operates a bakery in Grand Rapids where hourly workers are represented by Bakery, Confectionary, Tobacco Workers and Grain Millers International Union AFL-CIO-CLC Local No. 70. The union sought to compel the company to arbitrate two employee grievances that the union claimed arose under an expired collective bargaining agreement.
The case centers on the interpretation of arbitration requirements in expired labor contracts. According to the court record, Kellanova and the union have entered into several collective bargaining agreements over the years, all of which contained provisions requiring the parties to arbitrate unresolved grievances. The first agreement, referred to as the "2017 CBA," was initially effective from May 1, 2017, to April 30, 2020. In April 2020, the parties agreed to extend the 2017 CBA, though the complete details of that extension were not fully outlined in the available court documents.
The procedural history shows that the district court initially sided with the union's position, agreeing that Kellanova should be compelled to arbitrate the employee grievances in question. The district court's reasoning for ordering arbitration was not detailed in the appellate opinion, but the lower court evidently found merit in the union's argument that the grievances arose under the terms of the collective bargaining agreement.
However, the Sixth Circuit panel, consisting of Circuit Judges Batchelder, Clay, and Ritz, disagreed with the district court's analysis. Judge Ritz authored the opinion reversing the arbitration order, though the specific legal reasoning behind the reversal was not included in the available portions of the court document.
The case represents a victory for Kellanova in its ongoing labor relations with the bakery workers' union. As the defendant-appellant, Kellanova had challenged the district court's order requiring arbitration, arguing that it should not be bound to arbitrate grievances under the expired agreement terms.
For the union, which served as plaintiff-appellee in the case, the reversal represents a setback in its efforts to resolve the employee grievances through the arbitration process. The union had originally filed the action seeking to compel arbitration, likely believing that the arbitration clause in the collective bargaining agreement remained enforceable even after the contract's expiration.
This decision adds to the body of federal appellate case law addressing when arbitration clauses in expired collective bargaining agreements remain binding on employers and unions. The intersection of labor law and arbitration law often creates complex legal questions about the continuing obligations of parties after contract expiration.
The opinion was marked as "NOT RECOMMENDED FOR PUBLICATION," indicating that while it resolves the dispute between these specific parties, the Sixth Circuit does not view it as establishing precedent that would be broadly applicable to other similar cases. This designation typically means the decision addresses fact-specific circumstances rather than novel legal principles.
Kellanova's successful appeal demonstrates the importance of careful contract interpretation in labor disputes. The company was able to convince the appellate court that the district court erred in its analysis of whether the arbitration requirement survived the expiration of the collective bargaining agreement.
The case also highlights the ongoing challenges in labor relations within the food manufacturing industry, where collective bargaining agreements and their enforcement mechanisms play crucial roles in workplace dispute resolution. Bakery operations, with their around-the-clock production schedules and specialized work requirements, often involve complex labor arrangements that can lead to disagreements between management and workers.
Moving forward, the parties will need to address the underlying employee grievances through alternative means, since the arbitration path has been foreclosed by the Sixth Circuit's decision. The union may need to pursue other legal avenues or negotiate directly with Kellanova to resolve the workers' concerns.
The decision reflects the federal judiciary's approach to labor disputes involving expired contracts, where courts must balance the interests of workers seeking redress for grievances against employers' arguments about the limits of contractual obligations after agreement expiration.