## Facts

- Great Northern Railway Company, a federally regulated interstate common carrier, faced a nationwide railroad shopmen’s strike that began July 1, 1922.
- The railroad alleged that certain strike participants engaged in threats and acts of violence connected to the strike.
- The railroad filed an equity action seeking to restrain intimidation, violence, and obstruction affecting railroad operations and personnel.
- The court initially entered a temporary restraining order and continued it after a hearing.
- The matter proceeded on whether to issue a preliminary injunction and what law governed a federal court’s authority to grant injunctive relief in this railroad labor dispute.

## Issues

1. Whether federal law or state law supplies the governing rules for injunctive relief in a federal equity suit involving a labor dispute affecting an interstate railroad’s operations.
2. Whether a federal court may enjoin strike-related threats, violence, intimidation, and coercive obstruction interfering with the carrier’s performance of its duties.

## Decision

- The court held that federal law governed the dispute because the railroad’s rights and duties arose from its status and obligations as an interstate carrier subject to federal regulation.
- The court determined that equitable relief could issue to restrain unlawful strike conduct, including threats, violence, intimidation, and coercive interference with railroad operations.
- The court granted preliminary injunctive relief, continuing protection beyond the temporary restraining order while limiting the restraint to unlawful conduct rather than the strike itself.

## Legal Principles

- When a controversy materially implicates an interstate railroad’s federally defined duties and the maintenance of interstate transportation, federal law governs the availability and scope of equitable relief in federal court.
- A court of equity may restrain threats, violence, intimidation, and coercive obstruction connected to a labor dispute when such conduct interferes with a common carrier’s operations and endangers persons or property.
- Injunctive relief in a labor dispute is directed at unlawful means, not at prohibiting union affiliation, peaceful advocacy, or the mere decision to strike.

## Conclusion

The federal district court applied federal law to a railroad labor dispute affecting interstate transportation and issued a preliminary injunction aimed at preventing strike-related violence, threats, intimidation, and coercive interference with the railroad’s operations while distinguishing unlawful conduct from lawful strike activity.


Great N. Ry. Co. v. Brosseau, 286 F. 414 (D.N.D. 1923)