Writing Effective Labor Arbitration Briefs

Post-hearing briefs play a critical role in labor arbitration by providing arbitrators with a structured and persuasive presentation of facts, contract language, and arguments. A well-crafted brief can clarify the key issues in dispute, assist the arbitrator in drafting the award, and ultimately influence the outcome of the case. Unlike oral presentations, which are transient and may not be fully recalled, a written brief remains a lasting document that serves as the foundation for an arbitrator’s analysis. This article examines the structure of an effective post-hearing brief, identifies best practices, and discusses common pitfalls that advocates should avoid. By following these principles, advocates can maximize the persuasive impact of their written submissions.