Law Firms Mentioned:Maynard Nexsen | QSL Management | Quinn Connor Weaver Davies & Rouco
Organizations Mentioned:APM Terminals Mobile, LLC | International Longshoremen’s Association, AFL-CIO, Local Union 1410
To invoke the doctrine, an order must be unreviewable on appeal from a final judgment.
Dismissing a union’s appeal of a district court’s order denying a motion to compel arbitration, the Eleventh Circuit ruled it lacked jurisdiction because there was no basis for interlocutory review where a damages action against the union was pending. Neither the FAA nor the LMRA provided jurisdiction, and the district court’s order did not clear the stringent criteria for review under the collateral order doctrine (APM Terminals v. International Longshoremen’s Association, No. 24-11100 (11th Cir. Nov. 17, 2025)).
Local 1410, a union of longshoremen, move cargo for APM Terminals. A collective bargaining agreement governs the union’s work. Article 4 of the agreement provides that APM will not lock out union members and that union members will not strike. It also permits the parties to seek equitable relief or institute a judicial or administrative action for damages upon the satisfaction of certain conditions precedent. Article 5 separately includes an arbitration process.
Temporary restraining order. Following a disruption in operations, APM filed an action in state court alleging that union members had commenced a strike and moved for a temporary restraining order. The court...
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