Supreme Court of the United States
Buffalo Forge Co. v. United Steelworkers of America, Afl-Cio
July 6, 1976428 U.S. 397
Summary
The Supreme Court affirmed the Second Circuit, holding that a federal district court may not issue a preliminary injunction against a sympathy strike when the strike is not over an arbitrable grievance, even though the collective‑bargaining agreement contains a no‑strike clause. The Court reasoned that the narrow exception in Boys Markets applies only to disputes subject to the grievance‑arbitration procedure, which the sympathy strike was not. Justice Stevens dissented, arguing that the injunction should be permissible under the contract’s quid‑pro‑quo.
Holding
- Whether a federal court may enjoin a sympathy strike pending arbitration when the strike is not over an arbitrable grievance. No. A federal district court lacks authority to issue an injunction because the sympathy strike is not subject to the grievance‑arbitration procedure and thus falls outside the narrow Boys Markets exception.
- Whether §301(a) of the Labor Management Relations Act authorizes an injunction notwithstanding the Norris‑LaGuardia Act’s prohibition. No. §301(a) does not override the Norris‑LaGuardia Act’s ban on injunctions in labor disputes when the strike is not an arbitrable grievance.
- Whether the employer is entitled to a court order compelling the Union to submit the dispute to arbitration. Yes. The employer may obtain an order requiring arbitration of the no‑strike issue, but such an order does not include an injunction against the strike.
Docket 75-339
Cited authorities
- 28 U.S.C. § 1292
- 29 U.S.C. § 173
- 61 Stat. 156
- 29 U.S.C. §185
- 47 Stat. 70
- 29 U.S.C. § 104
- 28 U.S.C. § 1292