Avco Corp. v. Aero Lodge No. 735, International Ass'n of MacHinists & Aerospace Workers

1968-05-20

Headline: Labor-contract no‑strike dispute is removable to federal court; Court affirms removal and confirms federal law governs grievance claims under the national labor statute, affecting employers and unions.

Holding: The Court held that a suit enforcing a collective bargaining no‑strike clause arises under federal labor law and may be removed from state court to federal court under the removal statute.

Real World Impact:

Allows unions or employers to move labor‑contract disputes from state to federal court.
Makes federal law the rule for resolving grievance claims under national labor law.
Leaves open whether courts’ power to issue injunctions is limited by anti‑injunction rules.

Topics: labor contracts, union strikes, federal courts, state‑to‑federal removal

Summary

Background

An employer sued a union in a Tennessee state court to stop a plant strike, relying on a no‑strike clause in their collective bargaining agreement that required grievances to be settled amicably or by binding arbitration. A dispute over who was eligible for promotion led to work stoppages and a walkout. The state court issued an ex parte injunction to halt the strike. The union then asked a federal district court to take the case, and the district court denied a motion to send the case back and dissolved the state injunction. The Court of Appeals affirmed, and the Supreme Court took the case to resolve a disagreement between federal appeals courts.

Reasoning

The main question was whether a suit that enforces a collective bargaining agreement is governed by federal labor law and can be moved from state to federal court. The Court said such claims arise under the national labor statute (what the opinion calls §301) and are controlled by federal substantive law even when filed in state court. The Court explained that federal courts have primary authority to decide these federal-law questions and that removal under the federal removal statute was proper. The opinion distinguished the question of whether federal courts have jurisdiction from the separate question of what remedies a court may grant in a labor dispute.

Real world impact

The ruling makes it clear that many contract-based labor disputes can be litigated in federal court rather than only in state court, and that federal law will guide how grievance claims are interpreted. The Court also left open how existing anti‑injunction rules affect what relief a court may grant in specific labor disputes, so some remedies may still be limited.

Dissents or concurrances

A concurring opinion agreed with removal but noted uncertainty about whether the district court dissolved the injunction because of an earlier case about anti‑injunction law; the Court reserved that question for a future case.