Bus Employees v. Missouri
Headline: Ruling blocks Missouri law allowing the State to seize a transit company and stop its workers’ strike, holding those seizure-and-injunction powers conflict with federal labor law and cannot forbid the right to strike.
Holding: The Court decided that Missouri’s King-Thompson Act cannot lawfully make a peaceful strike against a public utility illegal by authorizing seizure and injunctions, because those provisions conflict with federal labor law protecting the right to strike.
- Blocks state seizure-and-injunction powers that make strikes illegal against covered utilities.
- Protects workers’ federally guaranteed right to strike against private utilities in interstate commerce.
Summary
Background
A union representing most employees of Kansas City Transit, a company operating in Kansas and Missouri, negotiated a new contract after the old one expired. Negotiations broke down and the workers voted to strike on November 13, 1961. That same day the Missouri Governor, citing the King-Thompson Act, issued orders claiming possession of the company’s plants and equipment and directing that state rules govern the company’s operation. The State then sought an injunction that led a Missouri court to bar the strike "against the State of Missouri," and the Missouri Supreme Court upheld that ruling.
Reasoning
The Court addressed whether the King-Thompson Act’s seizure-and-injunction provisions could lawfully prevent a peaceful strike against a public utility covered by federal labor law. The Court found the State had not actually become the employer: employees were not paid by Missouri, the State did not manage operations, and no property was transferred. Relying on the principle that federal law protects the right to strike, the Court held Missouri could not, by asserting emergency seizure, forbid strikes that federal law allows. The Court therefore reversed the state-court decision that had upheld the injunction.
Real world impact
The decision means Missouri cannot use the King-Thompson Act’s seizure-and-injunction powers to bar strikes by employees of a utility covered by federal labor law. The ruling leaves intact a State’s ordinary powers to own or operate utilities or to address genuine emergencies under state law, but it prevents state laws from denying federally protected labor rights.
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