On Wednesday, an appellate panel affirmed the findings of a Eastern District of Pennsylvania trial court in an arbitration dispute between Verizon Pennsylvania LLC and two unions, the Communications Workers of America, AFL-CIO, Local 13000 and Communications Workers of America, AFL-CIO District 2-13. The Third Circuit Court of Appeals struck the arbitration award because the issuing arbitration board improperly revised its decision without the parties' consent in violation of the "functus officio" doctrine.