The author maintains that, under Collyer, deferral has been distorted to mean a national policy in favor of arbitrating all disputes involving contract terms, making compulsory a process that was intended to be available to labor and management as a voluntarily method of dispute resolution. Professor Alleyne asserts that the Board’s discretion has been improperly exercised in favor of pre-arbitration deferral. He includes a survey of the common types of jurisdictional cases and how are they being decided by arbitrators and by the NLRB.