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The Norris-LaGuardia Act, 29 U.S.C.S. § 101 et seq., restricts the power of federal courts to issue injunctions in cases involving or growing out of a labor dispute.
A collective bargaining agreement between the NFL or the League and a union representing professional football players expired. The League had made known that if a new agreement was not reached before the expiration date, then it would implement a lockout of players, during which the athletes would not be paid or permitted to use club facilities. The players, aware of the League's strategy, opted to terminate the union's status as their collective bargaining agent just before the agreement expired. Subsequently, the players filed an action in the district court alleging that the lockout planned by the League would constitute a group boycott and price-fixing agreement that would violate § 1 of the Sherman Antitrust Act. Nevertheless, the League proceeded with its planned lockout. The players moved for a preliminary injunction in the district court, urging the court to enjoin the lockout as an unlawful group boycott that was causing irreparable harm to the players. The district court granted a preliminary injunction, and the League appealed.
Did the district court properly grant preliminary injunction to enjoin the lockout planned by the League?
The court vacated the order granting the preliminary injunction. Contrary to the district court's finding, the lawsuit was a controversy concerning terms or conditions of employment. By the plain terms of 29 U.S.C.S. § 113(a) of the Norris-LaGuardia Act, 29 U.S.C.S. § 101 et seq., the case was held to involve or grow out of a labor dispute. According to the court, the district court reached a contrary conclusion by departing from the text of § 113(a); there was no requirement of unionization in the text. Whatever the effect of the union's disclaimer on the league's immunity from antitrust liability, the labor dispute did not suddenly disappear just because the players elected to pursue the dispute through antitrust litigation rather than collective bargaining. The court held that 29 U.S.C.S. § 104(a) deprived federal courts of power to issue an injunction prohibiting a party to a labor dispute from implementing a lockout of its employees. The injunction as it pertained to free agents and prospective players violated 29 U.S.C.S. § 107 as there was no testimony of witnesses in open court with opportunity for cross-examination.