Public policy in the United States favors alternative dispute resolution as an effective means of resolving labor disputes instead of litigation. For this reason, the majority [Page 539]of states with collective bargaining agreements between public school teachers and their boards of education mandate the use of formal grievance procedures to settle labor disputes. Three famous U.S. Supreme Court labor cases, referred to as the steelworkers' trilogy (United Steelworkers of America v. American Manufacturing Company [1960], United Steelworkers of America v. Warrior and Gulf Navigation Company [1960], and United Steelworkers of America v. Enterprise Wheel and Car Company [I960]) reflect the connection between federal labor law and state collective bargaining law.

Along with fact-finding and arbitration, mediation is one of the three primary methods of dispute resolution ...