## Facts

- Public-school employees of the Terrebonne Parish School Board, organized as the Terrebonne Parish Association of Educators, engaged in a strike seeking collective bargaining.
- The union sued the school board seeking monetary and injunctive relief connected to the labor dispute.
- The school board filed a reconventional demand seeking a declaration that the strike was illegal and an injunction to end the work stoppage.
- The trial court concluded Louisiana’s “Little Norris–LaGuardia Act” governed the dispute and, because the statutory conditions for injunctive relief were not satisfied, held it lacked authority to grant equitable relief.
- The court of appeal reversed and granted injunctive relief to the school board.
- The Louisiana Supreme Court granted review on the union’s application.

## Issues

1. Whether Louisiana’s Little Norris–LaGuardia Act applies to labor disputes involving public-sector employees employed by a school board.
2. If the Act applies, whether it restricts or bars courts from issuing injunctions and other equitable relief against a public-employee strike unless statutory prerequisites are met.
3. Whether the lower court properly refused injunctive relief under the Act’s limitations.

## Decision

- The Louisiana Supreme Court reversed the court of appeal.
- The Court held that the Little Norris–LaGuardia Act applies to the school-board labor dispute involving public employees.
- Because the Act applied and the statutory prerequisites for injunctive relief were not satisfied, the trial court properly determined it lacked authority to grant the requested equitable relief.
- The trial court’s disposition denying equitable relief under the Act was reinstated, and the school board did not obtain an injunction against the strike.

## Legal Principles

- Louisiana’s Little Norris–LaGuardia Act applies broadly to “labor disputes” and is not limited to private-sector employment absent a clear statutory exclusion.
- When the Act applies, courts’ power to issue labor injunctions is tightly limited and may be exercised only upon satisfaction of the Act’s specific substantive and procedural requirements.
- Policy concerns about public-sector strikes do not permit courts to bypass statutory limits on injunctive relief; regulation of public-sector labor activity is primarily a legislative responsibility.

## Conclusion

The Louisiana Supreme Court held that the Little Norris–LaGuardia Act governs public-school labor disputes and restricts judicial authority to enjoin strike activity unless the Act’s conditions for injunctive relief are met, reversing an appellate injunction and reinstating the trial court’s refusal of equitable relief.


Davis v. Henry, 555 So. 2d 457 (La. 1990)