Holtec Int'l Corp. v. MSUWC: Misnomer, Waiver, and the Enforcement of Labor Arbitration Awards Despite Caption Errors

I. Introduction

In Holtec International Corporation v. Michigan State Utility Workers Council, No. 25‑1469 (6th Cir. Nov. 24, 2025), the United States Court of Appeals for the Sixth Circuit addressed a deceptively simple but practically important question:

Where an arbitration demand and award caption misname the party against whom relief is sought, but there is no real-world doubt about which entity is intended and has actually participated, may a federal court enforce the award against the correctly intended party?

The court answered yes. In a published opinion by Judge Karen Nelson Moore, joined in full by Judge Ritz and in substantial part by Judge Thapar (who declined to join only Part II.D), the Sixth Circuit:

Confirmed that labor arbitration awards must be read as a whole, not mechanically by their captions;
Held that a caption misnaming a corporate party is a curable misnomer, not a jurisdictional defect, where identity is otherwise clear and there is no prejudice;
Reaffirmed that parties who participate in arbitration without timely objection waive procedural and even “jurisdictional” objections, and cannot “sandbag” after an adverse result; and
Rejected the argument that enforcing such an award constitutes an impermissible modification of the arbitrator’s decision.

The case arises from a labor dispute at the Palisades Nuclear Power Plant in Michigan, where Holtec Decommissioning International, LLC (“HDI”), a subsidiary of Holtec International Corporation (“Holtec International”), took over decommissioning operations from Entergy. The Michigan State Utility Workers Council (the “Union”) represented the plant’s workers and had a collective bargaining agreement (“CBA”) with HDI.

When HDI terminated union member James Charles after he went on long-term disability, the Union filed a grievance and then a demand for arbitration. Due to a clerical error, the demand’s caption named “Holtec International” as the employer-respondent, even though:

HDI, not Holtec International, was Charles’s actual employer;
HDI was the party to the CBA; and
HDI appeared, defended, and litigated the arbitration on the merits.

After the arbitrator awarded reinstatement and benefits for Charles, HDI refused to comply and—together with Holtec International—sued to vacate the award under § 301 of the Labor Management Relations Act (LMRA), 29 U.S.C. § 185. The sole substantive attack: the award was “against” Holtec International (per the caption) and thus beyond the arbitrator’s authority.

This commentary provides a structured and in-depth analysis of the decision, its doctrinal foundation, and its likely impact on labor arbitration and federal arbitration law more broadly.

II. Summary of the Opinion

A. Factual and Procedural Background

Plant and parties: Palisades Nuclear Power Plant on Lake Michigan; Union represented employees; Entergy shut down operations; HDI, a Holtec International subsidiary, took over decommissioning in 2022 and assumed the existing CBA with the Union.
Employee status: James Charles, an HDI employee and Union member, left active work due to a nonoccupational medical condition. He was on short-term disability, then approved for long-term disability in March 2023. HDI terminated him thereafter.
Union grievance: The Union asserted that the CBA obliged HDI to keep Charles employed for two years (allowing seniority accrual) and provide benefits for that period.
Arbitration demand: When the parties could not resolve the grievance, the Union filed for arbitration. The demand mistakenly named “Holtec International Corporation” as the respondent, rather than HDI.

Despite the caption error:

HDI’s counsel appeared at the hearing and explicitly stated he represented HDI, not Holtec International;
Both parties agreed on the record that the matter was “procedurally properly before” the arbitrator and that there were “no timeliness or procedural questions” precluding a merits decision;
All post-hearing briefs and the factual recitations in the award treated HDI as the employer and as the party to the CBA; and
The arbitrator retained jurisdiction for 90 days solely to address implementation or interpretation of the remedy.

The arbitrator ultimately ruled for the Union, ordering that Charles be “immediately restored to employment status” and receive two years of benefits. The caption, however, still listed “Holtec International” as the “Employer,” while the body consistently identified HDI as Charles’s employer and the party to the CBA, or simply “the Employer.”

HDI did not implement the award and instead, joined by Holtec International, filed a § 301 action to vacate the award in federal court. The Union counterclaimed to confirm it. The district court granted summary judgment for the Union, confirming the award against HDI and rejecting Holtec’s caption-based attack. Holtec appealed.

B. The Legal Issue

The Sixth Circuit distilled the appeal to a narrow, but important, question:

Where an arbitration demand and award caption misname the party against whom relief is sought, but the identity of the intended bound party is not genuinely in doubt, may a federal district court enforce the award against that intended party?

C. Holding

The Sixth Circuit affirmed the district court and held:

The award, read as a whole, unambiguously bound HDI, not Holtec International. The caption error did not control; the arbitrator’s opinion and award, taken together, clearly targeted HDI as the employer and party to the CBA.
Any procedural or jurisdictional objection to the caption misnomer was waived. HDI knew from the outset of the naming error, affirmatively told the arbitrator there were no procedural barriers, and failed to raise any objection even during the 90-day retained-jurisdiction period.
The misnaming of “Holtec International” in the caption was a classic misnomer, not a fatal jurisdictional defect. Under longstanding misnomer doctrine from Michigan contract law and analogous federal cases, a misnomer that does not mislead or prejudice the intended party does not defeat enforcement.
The district court did not impermissibly modify the award. Because the correctly interpreted award already ran against HDI, enforcement against HDI simply required HDI to do what the award inherently required; no formal modification was necessary.

D. Disposition

The court:

Affirmed the district court’s denial of Holtec’s motion to vacate; and
Affirmed the grant of summary judgment to the Union on its counterclaim to confirm the arbitration award.

The opinion is recommended for publication, thus establishing binding precedent in the Sixth Circuit. Judge Thapar concurred in all but Part II.D (the misnomer discussion), indicating some intra-panel disagreement on the breadth or necessity of that doctrinal analysis, though the judgment and core reasoning remain controlling.

III. Detailed Analysis

A. Legal Framework

1. LMRA § 301 and judicial review of labor arbitration

The case arises under § 301 of the Labor Management Relations Act, 29 U.S.C. § 185, which authorizes suits over collective bargaining agreements, including actions to vacate or confirm labor arbitration awards. Federal courts reviewing such awards:

Apply a highly deferential standard, intervening only in narrow circumstances (e.g., arbitrator exceeded contractual authority, award violates public policy); and
Often look to the Federal Arbitration Act (FAA), 9 U.S.C. § 1 et seq., for guidance, even though the FAA does not directly govern labor arbitration. The opinion expressly cites FAA § 10(a)(4) as a reference point (vacatur for “exceed[ing] [arbitrators’] powers”).

On appeal, the Sixth Circuit reviewed:

The district court’s factual findings for clear error; and
Legal questions, including summary judgment and interpretation of the award, de novo. (Int’l Bhd. of Teamsters, Local 519 v. UPS, 335 F.3d 497, 503 (6th Cir. 2003)).

2. Arbitrator’s “jurisdiction” and party consent

Holtec framed its attack as a jurisdictional problem: because the caption named Holtec International, and Holtec International was not a party to the CBA, the arbitrator purportedly had no authority to issue an award “against” that entity. In arbitration law, this is often characterized as a question of whether the arbitrator acted beyond the scope of the parties’ agreement.

The Sixth Circuit’s response had two layers:

As a matter of interpretation, the award did not actually run against Holtec International at all; and
Even if the caption error had some jurisdictional aspect, HDI waived any such objection by participating fully without timely protest.

B. Interpreting the Award as a Whole

1. Sixth Circuit’s approach: read award and opinion together

The court grounded its interpretive approach in prior Sixth Circuit precedent:

M & C Corp. v. Erwin Behr GmbH & Co., 143 F.3d 1033 (6th Cir. 1998) – When reading an arbitral award, courts consider the “opinion and award, read together.” If they are not ambiguous, the award should be enforced.
Island Creek Coal Sales Co. v. City of Gainesville, 764 F.2d 437 (6th Cir. 1985) – Similar instruction to interpret awards as a composite of text and context.
Pace Local Union 1967 v. Champion Int’l Corp., 8 F. App’x 404 (6th Cir. 2001) – An award’s caption or isolated language cannot override the clear substance of the arbitrator’s reasoning and intention when the opinion is read as a whole.

Under this approach, courts do not treat the caption as a dispositive “defined term” but examine whether, substantively, the arbitrator was adjudicating a dispute the parties actually submitted and within the scope of their agreement.

2. Application to Holtec: substance over caption

Applying this method, the Sixth Circuit found that, “read in its entirety,” the award could only sensibly be understood as binding HDI:

The factual recitation names HDI “ten times” as the employer;
The “issues presented” are expressly framed as whether “the Company, HDI” breached the agreements;
The award excerpts “relevant contract language” exclusively from the CBA between HDI and the Union;
Holtec International was not Charles’s employer, was not a signatory to the CBA, and did not appear in the arbitration; and
HDI’s own conduct—appearing through counsel, litigating the merits, and not objecting—demonstrated everyone understood HDI as the real party in interest.

The court thus described Holtec’s caption-based argument as straining “credulity.” The caption, the court reasoned, was simply a carryover from the initial arbitration demand, which contained the same error and was replicated in subsequent documents—a clerical artifact, not an intentional jurisdictional decision by the arbitrator.

On this basis, the court concluded that enforcing the award against HDI was not a reinterpretation that changed its substance, but rather a faithful implementation of what the arbitrator unambiguously intended and what the parties understood throughout the proceeding.

C. Waiver and the Anti-Sandbagging Principle

1. The doctrine: objections must be timely, not opportunistic

The court then addressed a second, independent ground: even assuming a defect, Holtec had waived its objection by failing to raise it before or during arbitration. The opinion situates this in a broader anti-sandbagging jurisprudence:

Hanover American Ins. Co. v. Tattooed Millionaire Ent., LLC, 974 F.3d 767 (6th Cir. 2020) – The Sixth Circuit “strongly discourage[s]” sandbagging: waiting to raise procedural objections until after losing on the merits.
Stern v. Marshall, 564 U.S. 462 (2011) – The Supreme Court warned against “litigant sandbagging” where the party “belatedly rais[es]” objections only if the case comes out unfavorably.
Thomas v. Arn, 474 U.S. 140 (1985) – Sandbagging undermines finality and wastes judicial resources.

In the arbitration-specific context, the Sixth Circuit invoked:

Order of Railway Conductors & Brakemen v. Clinchfield R.R. Co., 407 F.2d 985 (6th Cir. 1969) – “Defects in proceedings prior to or during arbitration may be waived by a party’s acquiescence in the arbitration with knowledge of the defect.”
Nationwide Mut. Ins. Co. v. Home Ins. Co., 330 F.3d 843 (6th Cir. 2003) – This waiver rule applies even to objections framed as challenges to the “jurisdiction” of the arbitrator.
Barrick Enters., Inc. v. Crescent Petroleum, Inc., 496 F. App’x 614 (6th Cir. 2012) – Vacatur denied where a party knew of ex parte communications between a witness and the arbitrator but failed to object.
Armco Emps. Indep. Fed’n, Inc. v. AK Steel Corp., 149 F. App’x 347 (6th Cir. 2005) – Parties need not “present to the arbitrator all foreseeable restrictions on his authority,” but where there is “actual notice” of the potential relief, failure to object constitutes waiver.

The AAA Labor Arbitration Rules, which applied to this arbitration, also require jurisdictional objections to be raised early (no later than the answering statement to the claim or counterclaim that gives rise to the objection). HDI ignored this requirement.

2. Application: Holtec’s knowledge and failure to act

The court found multiple points at which Holtec could—and should—have raised any objection:

At the filing of the arbitration demand – HDI (and Holtec International) knew from the outset that the demand named “Holtec International” as respondent.
At the arbitration hearing – HDI’s counsel put on the record that he represented HDI and then affirmatively stated that there were no procedural defects and that the matter was properly before the arbitrator.
During the 90-day retained-jurisdiction window – Even if HDI first recognized the alleged defect when the written award arrived, the arbitrator expressly retained jurisdiction for 90 days to address remedial implementation issues. HDI did not ask the arbitrator to clarify or correct the caption.

Having “actual notice” of the miscaption, HDI nonetheless treated the case as properly before the arbitrator and only objected after it lost on the merits—exactly the sandbagging behavior the court’s precedents condemn. As the opinion, echoing Stern, put it: if HDI “believed that the [arbitrator] lacked the authority to decide [the claim], then [it] should have said so—and said so promptly.”

Thus, even if the caption error were characterized as a “jurisdictional” issue, the court held it was waived by participation with knowledge.

D. The Doctrine of Misnomer in Arbitration (Part II.D)

Part II.D of the opinion, which Judge Thapar did not join, adds a third layer of analysis: the use of the misnomer doctrine to validate the proceedings and award. This part is doctrinally significant because it imports traditional misnomer principles from contract and civil procedure into the arbitration context.

1. Misnomer vs. mistaken identity

The misnomer doctrine draws a distinction between:

Misnomer: The written name used is technically incorrect, but the identity of the person or entity is nonetheless clear to everyone involved. The wrong name points to the right party.
Mistaken identity: The wrong person or entity is actually intended or involved; the written name refers to a different real-world entity.

In misnomer cases, courts generally allow correction and enforce the instrument or proceeding as to the intended party, so long as there is no prejudice or genuine confusion. In mistaken identity cases, by contrast, the error can be fatal.

2. Michigan contract law and federal analogues

The Sixth Circuit relied on Michigan misnomer law, appropriate given the Michigan situs and the underlying CBA:

PIM, Inc. v. Steinbichler Optical Techs. USA, Inc., 660 N.W.2d 73 (Mich. 2003) – “The misnomer of a person or corporation in a written instrument will not defeat a recovery thereon if the identity sufficiently appears from the name employed in the writing or is satisfactorily established by proof” (citing St. Matthew's Evangelical Lutheran Church v. United States Fid. & Guar. Co., 192 N.W. 784 (Mich. 1923)).

The court then analogized to misnomer in judicial process:

62B Am. Jur. 2d Process § 70 – A misnomer in a summons can be disregarded where the defendant is not misled or prejudiced and knows, or has good reason to know, that it is the intended party.
United States v. A.H. Fischer Lumber Co., 162 F.2d 872 (4th Cir. 1947) – A misnamed corporate defendant in a summons does not invalidate service where “every intelligent person understands who is meant.”
Tremps v. Ascot Oils, Inc., 561 F.2d 41 (7th Cir. 1977) – Similar approach to misnomer in pleading and process.
Conner-Cooley v. AIG Life Brokerage, 282 F.R.D. 431 (E.D. Wis. 2012) – No defect where there are no facts indicating that the misnomer created any “reasonable doubt or confusion” about who the plaintiff intended to sue.

The court then pointed to arbitration-specific misnomer cases:

Cigna Ins. Co. v. Huddleston, 986 F.2d 1418, 1993 WL 58742 (5th Cir. Feb. 16, 1993) (table) – Arbitration award incorrectly named “CIGNA Property and Casualty Company” instead of “CIGNA Insurance Company.” The Fifth Circuit held that this “technical defect” did not render confirmation erroneous because “everyone involved in the action . . . knew of and could identify the entity being sued.”
Salzgitter Mannesmann Int’l (USA) Inc. v. Esmark, Inc., 2023 WL 5916566 (S.D. Tex. Sept. 11, 2023) – Award confirmation was upheld despite a caption error, where the party seeking vacatur could not plausibly argue the arbitrators intended to bind the wrong entity.

3. Application and limits in Holtec

The Sixth Circuit treated the caption naming “Holtec International” as a textbook misnomer:

The arbitration demand was served on HDI’s officer;
HDI’s attorney appeared before the arbitrator, and “neither he nor anyone else had any doubt that [HDI] was the corporation intended to be named” (paraphrasing A.H. Fischer);
There was no evidence of prejudice or confusion—HDI fully understood it was defending its own employment decision under a CBA to which it, not Holtec International, was a party; and
HDI could not offer a “conceivable explanation,” echoing Esmark, for why the arbitrator would intentionally issue an award against an unrelated entity that had not appeared and was not the employer.

The court memorably refused to transform the arbitration into a “children’s game,” quoting A.H. Fischer and stressing that the process was “a serious effort on the part of adult human beings to administer justice.” In other words, the law does not permit a party to exploit a technical caption error to escape a merits-based adjudication that everyone understood was directed at it.

Part II.D also addresses Holtec’s argument that the district court violated the “party-presentation” principle by invoking misnomer doctrine even though the Union had not named that doctrine in its briefing. The court rejected this, citing:

In re Chrysler Pacifica Fire Recall Product Liability Litigation, 143 F.4th 718 (6th Cir. 2025), and
Greenlaw v. United States, 554 U.S. 237 (2008).

The court explained that the party-presentation principle applies to “issues,” not to every legal concept or citation. The Union had squarely raised the issue—whether the arbitration and award should be understood as truly involving HDI. The district court’s reliance on misnomer doctrine was simply a legal tool to decide that issue, not a new, unbriefed issue of its own.

Because Judge Thapar did not join Part II.D, there is at least some judicial hesitance about how far to lean on misnomer doctrine in this setting. Nevertheless, the majority’s analysis is now a cited, published application of misnomer principles to labor arbitration in the Sixth Circuit.

E. No Impermissible Modification of the Award

Holtec argued that, because the Union never filed a motion to modify or correct the award (for example, under FAA-like standards), the district court effectively sua sponte modified the award by treating it as against HDI. The Sixth Circuit rejected this, noting that the premise was faulty: the award was already, properly interpreted, against HDI, so no modification was necessary.

The court relied on:

Island Creek Coal Sales Co. v. City of Gainesville, 764 F.2d 437 (6th Cir. 1985) – When a court “required [a party] to do specifically that which was inherently required of it by the award,” it did not “correct or modify” the award.
Pace Local Union 1967 v. Champion Int’l Corp. – Interpreting a contested award is not the same as altering it; courts may clarify to implement the arbitrator’s intent without crossing into modification.

In other words, the line between legitimate judicial interpretation (allowed) and impermissible modification (often barred or strictly time-limited) turns on whether the court is changing the substance of the rights and obligations the arbitrator actually imposed. Here, enforcing the award against HDI merely implemented what the arbitrator plainly decided: that HDI must reinstate and provide benefits to Charles.

IV. Precedents and Their Influence

The opinion is notable for its dense reliance on both Sixth Circuit and out-of-circuit authorities. Key contributions include:

Reading awards as a whole: M & C Corp., Island Creek, and Pace Local 1967 supply the framework for treating the caption as subordinate to the award’s substantive reasoning and factual findings.
Waiver of defects and jurisdictional objections: Clinchfield, Nationwide v. Home Ins., Barrick, and Armco collectively underscore that parties must raise known defects promptly, or they forfeit the right to complain later—even about putative limits on the arbitrator’s authority.
Anti-sandbagging and finality: Hanover American, Stern v. Marshall, and Thomas v. Arn situate arbitration waiver in a broader judicial antipathy toward gamesmanship and post hoc procedural ambushes.
Misnomer doctrine: PIM, St. Matthew’s, A.H. Fischer, Tremps, Conner-Cooley, Cigna, and Esmark show a consistent pattern: where everyone knows who is really involved and no prejudice exists, a miswritten name does not thwart substantive adjudication.
Party-presentation principle: Chrysler Pacifica and Greenlaw are used to defend judicial reliance on legal doctrines not explicitly cited by a party, as long as the underlying “issue” was fairly presented.
FAA for guidance: Teamsters Local 519 confirms the practice of looking to FAA § 10(a)(4) for analogical guidance on arbitrator overreach in labor cases.

Collectively, these precedents frame Holtec not as a novel doctrinal departure, but as a synthesis and application of well-established principles to a recurring practical problem in arbitration: caption errors and party identities in complex corporate structures.

V. Complex Concepts Explained

A. LMRA § 301 and labor arbitration review

Section 301 of the LMRA allows federal courts to hear suits involving collective bargaining agreements, including actions to vacate or confirm labor arbitration awards. But the review is intentionally narrow:

Courts do not reweigh the merits of the arbitrator’s interpretation of the CBA;
They intervene mainly if the arbitrator clearly went beyond the contract’s scope, ignored its plain language, or issued an award that violates explicit, well-defined public policy.

B. FAA § 10(a)(4): “Exceeding powers”

Although the FAA does not by its terms govern labor arbitration, courts often borrow its framework for guidance. Section 10(a)(4) allows vacatur where arbitrators “exceeded their powers.” Holtec tried to fit its argument into this mold: if the award was “against” Holtec International, the arbitrator would have exceeded his powers by purporting to bind a non-signatory.

The Sixth Circuit sidestepped the issue by finding, as a matter of interpretation, that the arbitrator did not actually attempt to bind Holtec International at all; he bound HDI, a proper party under the CBA.

C. Misnomer vs. mistaken identity in plain terms

Misnomer is like spelling someone’s name wrong on a contract (“Jon Smith” instead of “John Smith”), when everyone knows which actual human is involved and that person acts under the contract. Courts fix or ignore the typo.
Mistaken identity is like contracting with “John Smith of Ohio” when you actually intended “John Smith of California,” who never saw or signed the contract. That can be fatal, because you may have involved the wrong party entirely.

In Holtec, the court held the “Holtec International” caption was a misnomer, not mistaken identity: the underlying reality—HDI’s role as employer and CBA party, HDI’s participation, HDI’s service of process—made the intended target unmistakable.

D. Waiver and “sandbagging”

“Waiver” in this context means a party intentionally relinquishes or abandons a known right, or behaves in a way that makes it fair to treat them as having given it up. In arbitration, a classic waiver occurs when:

A party knows about a procedural defect (like a miscaption, flawed notice, or arbitrator disqualification issue);
Chooses to remain silent and proceed through the hearing; and
Only after losing, raises the defect as a basis to overturn the award.

Courts label this “sandbagging” because the party appears to be lying in wait to spring a procedural trap only if the merits go badly. Holtec falls squarely into that pattern as described by the Sixth Circuit.

E. Party-presentation principle

The party-presentation principle holds that courts generally decide cases based on the issues the parties raise, rather than inventing new disputes or theories not presented. But:

It applies to issues, not to every doctrinal label or case citation;
A court remains free to use different legal concepts (like misnomer doctrine) to decide the issues the parties have framed; and
Here, the “issue” was whether the award was properly understood as against HDI. Misnomer doctrine was simply one analytic tool the district court and Sixth Circuit used to answer that issue.

VI. Practical Impact and Future Implications

A. For unions and employers in labor arbitration

Holtec has several concrete implications:

Caption errors will rarely save a party who has fully participated. Employers and unions alike cannot expect to vacate an award merely because the caption misnames a corporate entity, where the body of the award, the arbitration record, and the parties’ conduct make clear who was actually involved.
Raise procedural and “jurisdictional” objections early—or lose them. Under Holtec, even arguments styled as limits on the arbitrator’s authority can be waived by participation with knowledge. Parties must promptly object if they believe the wrong entity has been named, or the arbitrator lacks power under the CBA.
Corporate structures are not a safe harbor for technical attacks. Parent/subsidiary arrangements are common in modern employment settings. Holtec signals that technical misnaming of a parent, where the subsidiary is the real employer and litigant, will not readily defeat enforcement.
Arbitrators may rely on misnomer principles when asked to correct captions. Knowing that courts will treat misnomer as curable, arbitrators are on firmer ground correcting or disregarding caption errors so long as due process and clarity are maintained.

B. For drafting and challenging arbitration demands and awards

Counsel should still take care with party names. While Holtec protects against unfair forfeiture of awards for purely technical misnomers, accurate party naming avoids needless collateral litigation.
If served with a miscaptioned demand, counsel must choose a strategy:
- Either promptly move to correct or dismiss on that basis (risking a new filing with a corrected caption); or
- Accept that participation on the merits, without reservation, will likely waive later objections.
When awards include obvious caption errors, consider returning to the arbitrator first. Many arbitration rules, and Holtec’s 90-day retained jurisdiction clause, allow arbitrators to clarify or correct such issues. Doing so can avoid later waiver arguments and clarify enforcement.

C. Broader doctrinal influence within the Sixth Circuit

Within the Sixth Circuit, Holtec:

Strengthens a line of cases emphasizing contextual interpretation of arbitration awards and resistance to hyper-technical attacks on their form;
Extends misnomer doctrine explicitly into the labor arbitration context, at least as a confirmatory rationale when identity is otherwise clear;
Reaffirms that jurisdictional labels do not immunize objections from waiver in arbitration, analogizing to Nationwide v. Home Ins. and other cases; and
Clarifies the party-presentation principle does not bar courts from using doctrinal tools that parties have not specifically named, as long as the underlying issue was properly raised.

Because the misnomer analysis is contained in a part not joined by one panel member, future panels may debate how central that doctrine is to the holding. Still, the core rules—interpret awards as a whole and treat known caption errors as waived when unobjected to—are strongly established by the portions of the opinion joined unanimously.

VII. Conclusion

Holtec Int’l Corp. v. Michigan State Utility Workers Council stands for a practical and principled proposition: a labor arbitration award is not nullified by a caption that misnames the corporate party, where everyone understood which entity was truly before the arbitrator, that entity participated fully, and the body of the award unambiguously targets it.

The decision weaves together three powerful strands:

Substance over form: Courts must read arbitration awards holistically, focusing on the arbitrator’s intent and the actual dispute, not on stray caption language.
Waiver and anti-sandbagging: Parties who knowingly proceed despite procedural defects cannot lie in wait and attack only after losing on the merits—even when the objection is framed as “jurisdictional.”
Misnomer as a curable technicality: A miswritten name that causes no confusion or prejudice does not defeat enforcement of a valid award, particularly in a sophisticated commercial and labor context.

By affirming the award in favor of the Union and against HDI, the Sixth Circuit reinforced both the integrity and the finality of labor arbitration. The opinion sends a clear signal: arbitration is “a serious effort … to administer justice,” not a procedural game in which a party can exploit inconsequential caption errors to escape contractual obligations. For unions, employers, and arbitrators within the Sixth Circuit, Holtec is now a central reference point whenever party identities and caption mistakes intersect with the enforcement of labor arbitration awards.