Lauf v. E. G. Shinner & Co.
Headline: Labor protest limits: Court reverses a broad injunction against union picketing and publicity, says Wisconsin and federal labor laws cover the dispute and federal courts must make specific findings before enjoining activity.
Holding: The Court held the conduct fell within state and federal definitions of a labor dispute, reversed the injunction, and ruled federal courts must follow state law and make required findings before enjoining labor activity.
- Limits federal courts from enjoining labor activity without required statutory findings.
- Affirms state law may allow peaceful picketing and publicity in labor disputes.
- Reverses a sweeping injunction and sends the case back for more findings.
Summary
Background
A Delaware company ran five meat markets in Milwaukee and employed about thirty-five people. An independent local union and its manager demanded the company force its workers to join the union. The workers refused. The union then put up signs, picketed with people who were not employees, and publicly accused the company of being unfair, which the company said scared away customers and caused irreparable harm. The District Court issued an injunction against the union’s actions, and the Court of Appeals affirmed.
Reasoning
The Supreme Court first said Wisconsin law defines a "labor dispute" broadly and that the state statute also allows certain peaceful publicity and picketing. The Court explained federal jurisdiction to grant injunctions is limited by a federal law that forbids injunctions in labor disputes except after specific findings. The District Court had treated the matter as not a labor dispute and issued a wide injunction that banned picketing and publicity that state law might permit. The Supreme Court held the District Court erred: it should have treated the controversy as a labor dispute under state and federal definitions and it failed to make the required factual findings before issuing an injunction.
Real world impact
The Court reversed and sent the case back for further proceedings. That means federal courts must apply state labor rules about what picketing and publicity are lawful, and must make the statutory findings required by federal law before they enjoin labor activity. The initial injunction cannot stand without those required findings.
Dissents or concurrances
A dissenting opinion argued the union’s campaign was unlawful coercion and that the injunction protecting the company should have been affirmed. The dissent emphasized property rights and employee freedom from coercion.
Opinions in this case:
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