Supreme Court of the United States
Sinclair Refining Co. v. Atkinson
June 18, 1962370 U.S. 195
Summary
The Court held that § 301 of the Taft‑Hartley Act does not repeal the anti‑injunction provisions of § 4 of the Norris‑LaGuardia Act, so federal courts lack jurisdiction to grant injunctions against strikes arising from labor disputes even when brought under § 301; the district court’s dismissal was affirmed. Justice Brennan’s dissent argued that the statutes should be accommodated to allow injunctions necessary to enforce arbitration provisions.
Holding
- Whether § 301 of the Taft‑Hartley Act implicitly repeals § 4 of the Norris‑LaGuardia Act’s anti‑injunction provisions. No; § 301 does not repeal § 4, so the anti‑injunction provisions remain applicable to § 301 actions
- Whether federal courts have jurisdiction to issue injunctions against strikes arising from a labor dispute in a § 301 action. No; because the anti‑injunction provisions of § 4 remain in force, federal courts lack jurisdiction to grant such injunctions
Docket 434
Cited authorities
- 61 Stat. 156
- 29 U.S.C. § 185
- 47 Stat. 70
- 29 U.S.C. § 104
- 47 Stat. 73
- 29 U.S.C. §113
- 47 Stat. 70
- 29 U.S.C. § 102