## Facts

- Boys Markets, Inc. and Retail Clerks Union, Local 770 were parties to a collective-bargaining agreement requiring arbitration for contract-interpretation disputes and prohibiting strikes, picketing, and other work stoppages during the contract term.
- A dispute arose when management personnel and non-unit employees rearranged frozen-food merchandise; the union demanded unit employees perform the work.
- After the employer refused, the union called a strike and began picketing the store.
- The employer demanded the union stop the work stoppage and sought to invoke the contract’s grievance and arbitration procedures; the strike continued.
- The employer filed suit seeking injunctive relief and specific performance of the arbitration provision; the case was removed to federal court.
- The federal district court ordered arbitration and enjoined the strike and picketing.

## Issues

1. Whether the Norris–LaGuardia Act categorically bars a federal court from enjoining a strike that breaches a contractual no-strike clause when the underlying dispute is subject to binding arbitration enforceable under § 301(a) of the LMRA.
2. Whether the Court should overrule Sinclair Refining Co. v. Atkinson, which had read the Norris–LaGuardia Act to prohibit such injunctions.

## Decision

- The Supreme Court reversed the court of appeals and overruled Sinclair.
- The Court held that, in a case involving a strike over an arbitrable grievance, the Norris–LaGuardia Act does not bar an injunction enforcing the no-strike obligation when the employer is prepared to arbitrate.
- The Court approved injunctive relief in this setting only on the condition that the employer be ordered to submit the underlying dispute to arbitration.
- The Court recognized the need for traditional equitable showings, including a finding of irreparable injury, before issuing injunctive relief.

## Legal Principles

- Federal courts may enjoin strikes and picketing that violate a no-strike clause when the strike concerns a dispute the parties agreed to arbitrate under a collective-bargaining agreement enforceable through LMRA § 301(a).
- Injunctive relief is limited to disputes that are arbitrable under the contract and where the party seeking relief is ready and willing to arbitrate.
- A federal court must order arbitration of the underlying grievance as a condition of granting an injunction against the strike.
- The Norris–LaGuardia Act’s anti-injunction policy must be construed in harmony with § 301’s policy favoring enforcement of arbitration agreements and peaceful resolution of labor disputes.
- Stare decisis does not preclude overruling statutory precedents when later developments show the earlier rule is unworkable and conflicts with central federal labor policy.

## Conclusion

The Court created a narrow exception to the Norris–LaGuardia Act’s general bar on labor injunctions, permitting federal courts to enjoin strikes breaching no-strike clauses when the dispute is subject to arbitration under § 301 and the court orders arbitration as a condition of relief.


Boys Markets, Inc. v. Retail Clerks Union, Loc. 770, 398 U.S. 235 (1970)