This Jackson Lewis LLP memorandum analyzes a recent Washington State Court of Appeals decision to vacate an arbitration award that reinstated an employee who had been terminated for hanging a noose in the vicinity of an African American co-worker. The employee filed a union grievance after his termination for violating the employer's anti-harassment policy, and the arbitrator ordered his reinstatement after a brief suspension. In a case of first impression, the Washington Court of Appeals held that Washington state has a dominant public policy against employment discrimination, as articulated by the Washington Law against Discrimination, and the arbitrator's decision improperly limited the employer's ability to comply with Washington's anti-discrimination laws.