Law School Case Brief
Textile Workers Union of Am. v. Lincoln Mills of Ala. - 353 U.S. 448, 77 S. Ct. 912 (1957)
From the face of the Labor Management Relations Act of 1947 (Act) it is apparent that § 301(a) and § 301(b) of the Act, 29 U.S.C.S. § 185(a) and (b), supplement one another. Section 301(b) makes it possible for a labor organization, representing employees in an industry affecting commerce, to sue and be sued as an entity in the federal courts. Section 301(b) in other words provides the procedural remedy lacking at common law. Section 301(a) certainly does something more than that. Plainly, it supplies the basis upon which the federal district courts may take jurisdiction and apply the procedural rule of § 301(b).
In an action brought by plaintiff Textile Workers Union of America ("Textile Union") in the United States District Court for the Northern District of Alabama, which sought specific performance of the arbitration provisions of a collective bargaining contract, the District Court, concluding that it had jurisdiction, ordered defendant Lincoln Mills of Alabama ("Lincoln Mills") to comply with those arbitration provisions. On appeal, the United States Court of Appeals for the Fifth Circuit reversed, holding that although the District Court had jurisdiction to entertain the suit, it lacked authority founded either in federal or state law to grant the relief sought.
Did the district court have authority to entertain the suit?
The Court held that the agreement to arbitrate grievance disputes contained in the collective bargaining agreement entered into between Textile Union and Lincoln Mills, under the authority of § 301 of the Labor Management Relations Act of 1947 ("Act"), should be specifically enforced. The Court stated that it would undercut the Act and defeat its policy if it read § 301 narrowly as only conferring jurisdiction over labor organizations. A case or controversy arising under § 301(a) was one within the purview of judicial power as defined in U.S. Const. art. III. Further, as the policy in favor of the enforcement of agreements to arbitrate grievance disputes was clear, there was no reason to submit them to the requirements of § 7 of the Norris-LaGuardia Act.
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