The payment of money damages, rather than reinstatement, is the prevailing remedy in non-union wrongful termination cases, and also in industrialized democracies other than North America. Professor Rehmus observes that reinstatement was established as the appropriate remedy in the 1940’s; that today’s statutory and legal framework is much different; and that, where there is a CBA in force, arbitrators re-think their use of reinstatement as the preferred remedy for wrongful discharge.