The author asserts that problems unique to industrial jurisprudence should give us pause in drawing upon the analogy of the due process protections afforded in other forums. Regarding one constituent of just cause, that author opines that the arbitrator should not be a party to a “rigged award” – one solicited by management and labor in a discipline case – that would deny the employee a fair hearing before an unbiased tribunal. On the other hand, a jointly solicited decision in a wage dispute would be more in the nature of a tripartite panel ruling.