Starbucks Corp. v. McKinney

Background

In 2022, several employees at a Memphis Starbucks invited a television news crew to the store after hours to promote a union effort. Starbucks fired multiple workers involved in the media event, including union organizers. The federal labor board (the Board) filed an administrative complaint and the Board’s regional Director asked a federal judge under a labor-law provision called §10(j) for a temporary court order—including reinstating the fired workers—while the Board’s proceedings continued. The District Court applied a Sixth Circuit test that asks whether there is “reasonable cause” to believe unlawful practices occurred and whether relief is “just and proper,” granted the order, and the Sixth Circuit affirmed.

Reasoning

The key question was whether district courts must use the familiar four-factor test for preliminary injunctions—likelihood of success on the merits, irreparable harm, balance of equities, and public interest—or a lower reasonable-cause standard. The Court held the traditional four-factor Winter framework governs §10(j) petitions because Congress’s text and history do not clearly displace ordinary equitable rules. The majority rejected the Board’s argument that courts should defer and apply a watered-down reasonable-cause test.

Real world impact

Lower courts must now assess §10(j) requests using the four Winter factors, which generally require a clearer showing before granting temporary relief. This affects how often the Board can obtain quick reinstatement or other interim orders; employers, workers, and the Board will face a more searching judicial review. The ruling vacated and remanded the Sixth Circuit’s decision, so the underlying case is not finally resolved.

Dissents or concurrances

Justice Jackson concurred in part and in the judgment but disagreed that the majority gave sufficient weight to Congress’s choice to let the Board police labor disputes, arguing courts should tailor their equitable review to that statutory context.