Hattiesburg Building & Trades Council v. Broome

Background

A state court stopped a union from picketing at a business that was not the union’s main employer, after finding the primary employer was not in interstate commerce and saying a federal pre-emption rule did not apply. The state court issued an injunction against picketing at the secondary employer’s premises. The record, however, shows the secondary employer’s own business activities met federal labor-board jurisdictional standards.

Reasoning

The core question was whether the state court could bar picketing when federal labor authorities might properly handle the dispute. The Justices explained that the National Labor Relations Board’s jurisdiction can be met by looking to the business operations of either the main employer or the secondary employer. Because the secondary employer met those standards and the union’s actions were arguably a federal unfair labor practice, the state court had no power to issue the injunction. The Court therefore granted review and reversed the state judgment.

Real world impact

The decision means that when a secondary business’s operations satisfy federal labor-board standards, state courts should not step in to enjoin picketing that could be handled as a federal labor dispute. Unions, secondary businesses, and state courts will be affected because some local injunctions may be replaced by federal labor-board procedures. This ruling clarifies that federal labor law, rather than state injunctions, may control such disputes going forward.