Buffalo Forge Co. v. United Steelworkers of America, Afl-Cio

Summary

The Supreme Court affirmed the Second Circuit, holding that a federal district court may not enjoin a sympathy strike that is not over a grievance subject to the contract’s arbitration procedure, even though the strike may violate an express no‑strike clause. The Court relied on the narrow exception articulated in Boys Markets and the Norris‑LaGuardia Act’s anti‑injunction policy. Justice Stevens’ dissent argued the opposite, contending that an injunction should be available when the union breaches its contractual duty not to strike.