In the Warrior and Gulf case, the Court held that if a contract includes a
broad arbitration clause, a dispute not covered in other sections is still arbitrable.
In this case, the employer subcontracted work while its employees
were in a partial-layoff status. While lower courts held subcontracting to
be a potential management right, the Supreme Court held that the broad
arbitration agreement, coupled with the no-strike provision, brought the
dispute within the arbitral arena.