Liner v. Jafco, Inc.
Headline: Court blocks state-court injunction against union picketing, ruling the National Labor Relations Board has exclusive authority and limiting state courts’ ability to stop peaceful pickets.
Holding: The Court held that Tennessee courts exceeded their power by issuing an injunction against peaceful picketing because the National Labor Relations Board has exclusive authority over conduct arguably covered by federal labor law.
- Prevents state courts from enjoining picketing covered by federal labor law.
- Reinforces that the National Labor Relations Board handles most private labor disputes.
- Makes employers less able to use state injunctions to avoid federal labor proceedings.
Summary
Background
A group of 17 building trades unions, represented by the Chattanooga Building Trades Council and a local Hod-Carriers union, authorized a single peaceful picket at a Cleveland, Tennessee construction site. A worker carried a sign saying the contractor was not under union contract. The general contractor’s client obtained an ex parte state injunction after posting a bond, the picketing stopped, and construction resumed. The unions asked the state court to dissolve the injunction, arguing the dispute belonged to the federal labor agency, but the state courts denied relief and the injunction was made permanent.
Reasoning
The Court examined whether the Tennessee courts had any power to decide the dispute when the National Labor Relations Board is given exclusive authority over conduct arguably covered by the federal labor law. The Justices concluded the question was still live because the unions had a real stake through the contractor’s bond promising to pay damages if the injunction was wrongfully sued out. Relying on earlier decisions about federal control of labor disputes, the Court ruled the state court should not have issued the injunction because it risked frustrating national labor policy and the Board’s exclusive role.
Real world impact
The Court reversed the state judgment and sent the case back for further proceedings consistent with its opinion. Practically, the decision limits state courts’ power to enjoin picketing and reinforces that disputes arguably covered by federal labor law should go to the National Labor Relations Board rather than be decided by state injunctions.
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