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Keywords

jurisdictioninjunctionappealmotionrespondent
injunctionappealmotioncivil procedurerespondent

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Granny Goose Foods, Inc. v. Brotherhood of Teamsters and Auto Truck Drivers Local No. 70 of Alameda, 415 U.S. 423, 94 S.Ct. 1113, 39 L.Ed.2d 435, 85 L.R.R.M. (BNA) 2481, 18 Fed.R.Serv.2d 410, 73 Lab.Cas. P 14,338

Facts

Petitioner employers filed a suit in California state court against the respondent Union for engaging in a strike that breached collective-bargaining agreements. The state court issued a temporary restraining order on May 18, 1970, which was removed to federal court two days later. The federal District Court denied the Union's motion to dissolve the restraining order, and after the Union resumed its strike on November 30, 1970, the District Court held the Union in criminal contempt for violating the order. The Court of Appeals reversed this decision, leading to the Supreme Court's review.

On May 15, 1970, petitioners Granny Goose Foods, Inc., and Sunshine Biscuits, Inc., filed a complaint in the Superior Court of California for the county of Alameda alleging that respondent, a local Teamsters Union, and its officers and agents, were engaging in strike activity in breach of national and local collective-bargaining agreements recently negotiated by multiunion-multiemployer bargaining teams.

Issue

Did the temporary restraining order issued by the California state court expire before the Union's alleged contempt, and was the denial of the Union's motion to dissolve the order sufficient to convert it into a preliminary injunction?

Whether state law or Rule 65(b) is controlling, the restraining order expired long before the date of the alleged contempt, since under the State Code of Civil Procedure a temporary restraining order is returnable no later than 15 days from its date, 20 days if good cause is shown, and must be dissolved unless the party obtaining it proceeds to submit its case for a preliminary injunction.

Rule

A temporary restraining order must expire by its own terms within a specified time frame, and the federal court's jurisdiction does not extend the duration of a state court order beyond its original expiration date.

Once a case has been removed to federal court, federal law, including the Federal Rules of Civil Procedure, controls the future course of proceedings, notwithstanding state court orders issued prior to removal.

Analysis

The Supreme Court analyzed the timeline of the restraining order and determined that it expired under both state law and federal rules long before the Union resumed its strike. The Court emphasized that the denial of the motion to dissolve the restraining order did not convert it into a preliminary injunction of indefinite duration. The Court concluded that the Union had no reason to believe the order was still in effect when it resumed its strike.

The temporary restraining order was issued by the Superior Court on May 18, 1970, and would have remained in effect in the state court no longer than 15 days, or until June 2. The case was removed to federal court on May 20, 1970. The temporary restraining order therefore expired on May 30, 1970, applying the 10-day limitation of Rule 65(b) from the date of removal.

Conclusion

The Supreme Court affirmed the Ninth Circuit's ruling, concluding that the Union did not violate any order when it resumed its strike, as the restraining order had expired prior to the alleged contempt.

Since neither s 1450 nor the District Court's denial of the Union's motion to dissolve the temporary restraining order effectively converted that order into a preliminary injunction, no order was in effect on November 30, 1970, over six months after the temporary restraining order was issued.

Who won?

The Union prevailed in the case because the Supreme Court found that there was no effective restraining order in place at the time of the alleged contempt.

The Court of Appeals reversed, one judge dissenting, on the ground that the temporary restraining order had expired long before November 30, 1970, the date of the alleged contempt.

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