## Facts

- The International Longshoremen’s Association (ILA) adopted a policy refusing to handle cargo arriving from or destined for the Soviet Union to protest the Soviet invasion of Afghanistan.
- Allied International, Inc., an American importer of Soviet wood products, relied on an American shipper and domestic stevedoring services whose employees were ILA members.
- ILA members refused to unload Soviet cargo associated with Allied’s imports, disrupting Allied’s shipments and business and forcing contract renegotiations.
- Allied sued the ILA for damages under LMRA § 303, alleging the conduct was an unlawful secondary boycott prohibited by NLRA § 8(b)(4)(B).

## Issues

1. Whether the union’s refusal to handle Soviet cargo was activity “in commerce” covered by the NLRA despite involving foreign commerce and foreign ships.
2. Whether a politically motivated refusal to handle goods constitutes an unlawful secondary boycott under NLRA § 8(b)(4)(B) when it pressures neutral employers.
3. Whether the First Amendment immunizes the union from liability under NLRA § 8(b)(4)(B) and LMRA § 303.

## Decision

- The Supreme Court unanimously affirmed the judgment for Allied.
- The Court held the conduct was activity “in commerce” within the NLRA because it targeted domestic stevedoring operations and affected an American importer, not foreign crews or foreign ship employment terms.
- The Court held the refusal to handle Soviet cargo fell within § 8(b)(4)(B) because its effect and objective were to burden neutral employers by inducing employees to refuse to handle goods and thereby disrupt business relationships.
- The Court rejected the First Amendment defense, concluding political motivation did not exempt coercive conduct regulating business dealings from generally applicable labor restrictions.

## Legal Principles

- NLRA § 8(b)(4)(B) prohibits union conduct that induces employees of a neutral employer to refuse to handle goods with an object of forcing any person to cease doing business or otherwise dealing with another.
- The statutory prohibition applies based on the conduct’s objective and effect on neutral employers, even when the union’s ultimate motive is political rather than economic.
- Traditional restraint in applying U.S. labor law to disputes centered on foreign ships and foreign crews does not control when the challenged activity is directed at domestic commerce and domestic employers.
- The First Amendment does not bar enforcement of § 8(b)(4)(B) against union conduct that operates as coercion of business relations rather than protected expression.

## Conclusion

The Court held that the ILA’s refusal to handle Soviet cargo, though motivated by opposition to Soviet foreign policy, was an unlawful secondary boycott under NLRA § 8(b)(4)(B), actionable for damages under LMRA § 303, and not insulated by the First Amendment.


Int’l Longshoremen’s Ass’n v. Allied Int’l, Inc., 456 U.S. 212 (1982)