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Reiterates position previously taken – that arbitrators are bound by the law. Rejects the Mittenthal formula (1968, p. 42). Cites arbitrators’ decisions on both sides of the debate. Discusses cases where courts have considered the merits of awards.

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Discussion of the arbitrator’s power; arbitrators’ role in protecting individual rights; and the applicability of court decisions on due process to arbitration. The author suggests that the importance of the arbitration process to employee rights warrants incorporating some recognized due process safeguards.

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