St. John v. Wisconsin Employment Relations Board

Background

A union of gas workers sued in federal court, asking a judge to declare and stop enforcement of Wisconsin’s Public Utility Anti-Strike Law. The union had earlier sued in state court before any strike. That state court ruled against the union on the merits, and the Wisconsin Supreme Court declined to decide several federal constitutional questions until there were concrete facts. Later strikes and contempt proceedings led to further litigation in state and federal courts involving the same parties.

Reasoning

The federal district court concluded the earlier state judgment barred the union from challenging the law again — a claim called res judicata, meaning a prior final decision prevents relitigation. The Supreme Court found that the Wisconsin Supreme Court had in another related case actually decided the constitutional issues, so the district court’s res judicata ruling was incorrect. Still, the Court held that, given its decisions that same day in two related cases, federal court intervention to grant the union’s requested injunctive or declaratory relief was not necessary or appropriate. Therefore the Court vacated the lower court judgment but instructed the district court to dismiss the union’s complaint.

Real world impact

The ruling leaves the dispute mainly to state proceedings and the companion federal decisions issued that day. The union cannot get the federal injunction or declaration it sought in this case now. The practical effect is to limit immediate federal relief and keep challenges to the anti-strike law tied to the factual records and other pending rulings.

Dissents or concurrances

Three Justices agreed that the state judgment was not a bar, but they disagreed with using the other two decisions as the reason to dismiss the federal suit.