Youngdahl v. Rainfair, Inc.

Background

An Arkansas clothing plant owned by a Wisconsin company had about 100 women and seven men employees, many of whom sought union representation. Twenty-nine employees struck and picketed in May; the picket size ranged from eight to 37. The record describes nails and tacks scattered on company property, two tires punctured, a large amount of abusive name-calling aimed at workers, a live snake placed inside the plant, and other harassment. The employer obtained a state court injunction that permanently barred not only threatening conduct but also all picketing and patrolling near the plant.

Reasoning

The Court examined whether the state court could stop the strikers’ conduct. It concluded words and group conduct can be so abusive and massed in a small community that violence is likely, so the state properly enjoined threatening, intimidating, and obstructive acts and interference with streets and entry to the plant. But the Court held the state went too far by banning all picketing and patrolling; peaceful picketing was not shown to be inevitably violent and largely falls under federal labor law protections. The Court therefore affirmed the injunction to the extent it barred violence and obstruction, and set aside the parts that prohibited peaceful picketing.

Real world impact

States may issue tailored orders preventing violent or intimidating strike tactics and blocking obstruction of access to workplaces. At the same time, courts should not impose sweeping bans on peaceful picketing, because federal labor law and the federal labor agency play a central role in many labor disputes. The Arkansas judgment was partly vacated and sent back for proceedings consistent with this opinion.

Dissents or concurrances

The Chief Justice, Justice Black, and Justice Douglas would have reversed entirely, believing the federal labor board had exclusive control over the dispute.