Boys Mkts., Inc. v. Retail Clerk's Union - 398 U.S. 235, 90 S. Ct. 1583 (1970)

Rule:

Having concluded that Sinclair Refining Co. v. Atkinson, 370 U.S. 195 (1962) was erroneously decided and that subsequent events have undermined its continuing validity, the United States Supreme Courts overrules that decision.

Facts:

Petitioner corporation and respondent union were parties to a collective-bargaining agreement that provided that all controversies would be resolved by arbitration and that no work stoppages would occur during the lifetime of the agreement. After respondent called a strike, petitioner filed a complaint that sought an injunction and specific performance of the contractual arbitration provision. The relief was refused on the basis of Sinclair Refining Co. v. Atkinson, 370 U.S. 195 (1962), which held that the anti-injunction provisions of the Norris-LaGuardia Act, 29 U.S.C.S. § 104, precluded a federal district court from enjoining a strike in breach of a no-strike obligation under a collective bargaining agreement, even though that agreement contained provisions enforceable under § 301(a) of the Labor Management Relations Act, 29 U.S.C.S. § 185(a), for binding arbitration of the grievance dispute concerning which the strike was called.

Issue:

Did the anti-injunction provisions of the Norris-LaGuardia Act, 29 U.S.C.S. § 104, preclude a federal district court from enjoining a strike in breach of a no-strike obligation under a collective bargaining agreement?

Answer:

No.

Conclusion:

The U.S. Supreme Court overruled Sinclair because it was in direct contradiction with congressional policy favoring the voluntary resolution of labor disputes. According to the Court, the anti-injunction provisions of the Norris-LaGuardia Act did not preclude a Federal District Court from enjoining a strike in breach of a no-strike obligation under a collective-bargaining agreement containing provisions, enforceable under 301(a) of the Labor-Management Relations Act, for binding arbitration of the grievance dispute concerning which the strike was called. Therefore, the judgment was reversed and remanded for an affirmance of the requested relief.