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Keywords

jurisdictioninjunctionappeal

jurisdictioninjunctionappealwillappellant

Related Cases

Latrobe Steel Co. v. United Steelworkers of America, AFL-CIO, 545 F.2d 1336, 93 L.R.R.M. (BNA) 2898, 79 Lab.Cas. P 11,739

Facts

The United Steelworkers of America and its Local Union No. 1537 represented production workers at Latrobe Steel Company. After unsuccessful negotiations, office workers established a picket line, leading production workers to refuse to enter the plant. Latrobe Steel sought a temporary restraining order against the production workers' refusal to cross the picket line, resulting in a preliminary injunction issued by the district court. The production workers complied initially, but later continued to stay off work, prompting Latrobe Steel to move for civil contempt against the union.

After efforts to negotiate a collective bargaining agreement between the office workers local and Latrobe Steel proved unsuccessful, the office employees established a picket line outside of the Latrobe facility at about 11:00 P.M. on September 4, 1975.

Issue

Did the district court have jurisdiction to enjoin the union from refusing to cross a 'stranger picket line,' and can a coercive civil contempt decree survive the invalidation of the underlying order?

This appeal presents two principal issues. First, we must decide whether the district court had jurisdiction to enjoin the appellant union from refusing to cross a 'stranger picket line.'

Rule

The Norris-LaGuardia Act prohibits federal courts from issuing injunctions in labor disputes, and a contempt order cannot survive if the underlying injunction is invalid.

The Norris-LaGuardia Act prohibits federal courts from issuing injunctions in labor disputes.

Analysis

The court determined that the work stoppage was not over an arbitrable dispute, as it was a sympathy strike related to a picket line established by another union. Therefore, the Norris-LaGuardia Act applied, and the district court lacked jurisdiction to issue the preliminary injunction. Consequently, the contempt order, which was based on the violation of this injunction, could not stand.

The work stoppage by the production workers at Latrobe Steel was not over an arbitrable dispute. Instead, the strike was precipitated by a picket line which was established by members of another union, the office workers, in the course of a controversy with Latrobe by the latter group.

Conclusion

The Court of Appeals vacated the preliminary injunction and the contempt order, remanding the case for further proceedings consistent with its opinion.

Accordingly, the injunction and the order of contempt will be vacated and the cause remanded for proceedings consistent with this opinion.

Who won?

The union prevailed because the court found that the district court lacked jurisdiction to issue the injunction, which invalidated the contempt order.

The court concluded that the preliminary injunction as well as the contempt judgment in this case must be vacated.

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