McLeod v. General Electric Co.

Background

The International Union of Electrical, Radio & Machine Workers (IUE) charged General Electric Company with refusing to bargain when the union included representatives who also represented other labor groups. The NLRB’s Regional Director sought a temporary injunction under the labor law to force the company to meet and bargain in good faith with the union and its invited advisers. A federal district court granted relief using a two-part test, but the Court of Appeals for the Second Circuit reversed and a Justice stayed that reversal pending review.

Reasoning

The Supreme Court granted review but declined to decide the proper legal test for temporary injunctions under §10(j) of the National Labor Relations Act. The Court noted that after the appeals court decision, on October 14, 1966, the company and the union reached a new three-year collective bargaining agreement. Because that agreement might make injunctive relief unnecessary, the Supreme Court set aside the Court of Appeals judgment, dissolved the prior stay, and directed a new judgment that sends the case back to the district court to decide in the first instance what effect the new contract has on the injunction.

Real world impact

The ruling means the district court must re-evaluate whether an injunction is still appropriate now that the employer and union have a new contract. The Supreme Court did not resolve the broader standard for such injunctions, so temporary relief rules remain undecided and could change in later proceedings.