United Gov’t Sec. Officers of Am. Int’l Union v. Am. Eagle Protective Serv. Corp., 956 F.3d 1242 (10th Cir. April 21, 2020)

As a matter of first impression, the Tenth Circuit held that a six-month statute of limitations applies to an action to compel arbitration under Section 301 of the Labor Management Relations Act, rather than the six-year statute of limitations applicable to state-law claims for breach of contract. Applying this holding, the Court affirmed the district court’s order granting summary judgment to employers, which dismissed the employees’ claim to compel arbitration of a union labor dispute as time-barred.