Sinclair Refining Co. v. Atkinson

Sinclair Refining Co. v. Atkinson
Decided June 18, 1962
Full case nameSinclair Refining Co. v. Atkinson
Citations370 U.S. 195 (more)
Holding
The Norris–La Guardia Act prohibits injunctive relief as a remedy for the breach of a no-strike clause.
Court membership
Chief Justice
Earl Warren
Associate Justices
Hugo Black · Felix Frankfurter
William O. Douglas · Tom C. Clark
John M. Harlan II · William J. Brennan Jr.
Potter Stewart · Byron White
Case opinions
MajorityBlack
DissentBrennan, joined by Douglas, Harlan
Laws applied
Norris–LaGuardia Act
Overruled by
Boys Markets v. Retail Clerks

Sinclair Refining Co. v. Atkinson, 370 U.S. 195 (1962), was a United States Supreme Court case in which the court held that the Norris–LaGuardia Act prohibits injunctive relief as a remedy for the breach of a no-strike clause.[1][2]

Background

Sinclair Refining Company brought suit under Section 301(a) of the Labor Management Relations Act of 1947 to enjoin work stoppages, strikes, peaceful picketing and similar activities by labor unions and their officers and members. Sinclair alleged that these actions were in violation of a collective bargaining agreement containing a no-strike clause and providing a grievance procedure culminating in compulsory, final and binding arbitration of "any difference regarding wages, hours or working conditions."[1]

Opinion of the court

The Supreme Court issued an opinion on June 18, 1962.[1]

Subsequent developments

In Avco Corp. v. Machinists, the Supreme Court held that a suit for breach of a collective bargaining agreement can be removed to federal court under federal question jurisdiction. Once a case is removed to federal court, it must obey federal procedural law. Sinclair combined with Avco Corp. meant that a labor dispute case could be filed in a state court where an injunction could have been issued but immediately be removed to a federal court prohibited from issuing an injunction. The Supreme Court described this as "anomalous" in Boys Markets v. Retail Clerks and overturned Sinclair.[3]

References

  1. ^ a b c Sinclair Refining Co. v. Atkinson, 370 U.S. 195 (1962).
  2. ^ Lareau, N. Peter (May 2014) [2003]. Labor and Employment Law. pp. 19–45.
  3. ^ Boys Markets v. Retail Clerks, 398 U.S. 235 (1970).

This article incorporates written opinion of a United States federal court. As a work of the U.S. federal government, the text is in the public domain.