Bakery & Pastry Drivers & Helpers Local 802 of the International Brotherhood of Teamsters v. Wohl
Headline: Union’s peaceful, truthful picketing of small bakery delivery peddlers is protected; Court reversed a state-court injunction, making it easier for unions to inform customers and press for one-day relief hires.
Holding: The Court reversed the injunction, holding that peaceful, truthful picketing to inform customers about bakery route drivers working seven days and to seek one-day union relief hires is protected by the Fourteenth Amendment.
- Protects peaceful, truthful picketing about labor disputes.
- Makes it harder for states to use narrow laws to bar peaceful labor speech.
- Allows unions to warn customers and seek relief-hire arrangements for displaced drivers.
Summary
Background
A union of bakery truck drivers challenged an injunction that barred it from picketing bakeries and their customers to protest two independent peddlers who worked seven days a week. The peddlers bought bread from bakeries and delivered to small retailers, earning modest weekly profits. The union said many former union drivers had been forced into independent peddling after employers sold trucks, and the union sought either to recruit the peddlers into the union or to get them to work six days a week and employ a union relief driver one day.
Reasoning
The core question was whether truthful, peaceful picketing that informed customers about the peddlers’ seven-day schedules and sought employment for union relief drivers was protected speech. The trial court found the picketing truthful, brief, and peaceful but still issued an injunction because it viewed the dispute as outside the state labor statute. The Supreme Court reversed, holding that peaceful, accurate public statements and brief picketing to communicate labor grievances are protected by the Fourteenth Amendment; a state may not use a narrow statutory label to deny that protection.
Real world impact
The decision lets unions use truthful, nonviolent picketing near bakeries to inform customers and press for short relief-hire arrangements for displaced drivers. It also limits a State’s power to bar peaceful labor speech by defining certain enterprises as immune. The ruling was not a ruling on all possible picketing restrictions, but it protected the particular speech and conduct shown here.
Dissents or concurrances
A concurring opinion warned that the Court must not permit States to ban effective picketing simply because it works, reiterating past free-speech protections relating to labor information.
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