Granny Goose Foods, Inc. v. Brotherhood of Teamsters & Auto Truck Drivers, Local No. 70

1974-03-04

Headline: Court limits how long state temporary restraining orders last after removal, ruling they expire under state law or Federal Rule 65(b) limits and reversing a contempt fine against a union.

Holding: The Court held that a state temporary restraining order remains in effect after removal no longer than state law would allow and, in any event, no longer than Federal Rule 65(b) measured from removal, so the union's contempt judgment was reversed.

Real World Impact:

Prevents federal courts extending state ex parte orders beyond Rule 65(b) limits.
Reverses $200,000 contempt fine against a union for November strike.
Requires clear federal orders for longer injunctions and penalties.

Topics: restraining orders, removal to federal court, labor union strikes, injunction duration

Summary

Background

Three employers (Granny Goose Foods, Sunshine Biscuits, and Standard Brands) obtained a temporary restraining order in California in May 1970 to stop strike activity by a local Teamsters union. The union removed the case to federal court. After removal the federal court denied the union’s motion to dissolve the state restraining order. The union struck again in November and the district court held the union in contempt and fined it $200,000. The Court of Appeals reversed, and the Supreme Court reviewed the statutory question about how long a state order lasts after removal.

Reasoning

The central question was whether 28 U.S.C. §1450 keeps a state court temporary restraining order alive indefinitely after removal. The Court held that a state ex parte temporary restraining order remains effective after removal only as long as state law would have kept it in force and, in any event, no longer than the time limits set by Federal Rule of Civil Procedure 65(b) measured from the date of removal. The Court also found the district court’s denial of the motion to dissolve did not convert the short-term restraining order into a preliminary injunction because the parties did not present the full preliminary-injunction hearing.

Real world impact

The decision means people and businesses cannot be punished for violating a state short-term restraining order that has expired under state law or under Rule 65(b) after removal. Federal courts must clearly issue a preliminary injunction with findings if they intend to impose longer restrictions or penalties. The Court therefore reversed the contempt judgment against the union.

Dissents or concurrances

Justice Rehnquist agreed the contempt judgment should be reversed but disagreed with the Court’s broad rule tying state orders to Rule 65(b), preferring that parties seek modification under §1450 instead.