## Facts

- Latrobe Steel Company operated a Pennsylvania steel plant and had a collective bargaining agreement (CBA) with a union local representing production and maintenance employees.
- The CBA contained a broad no-strike clause and a grievance-arbitration procedure.
- A different bargaining unit of Latrobe’s office, clerical, and technical employees established a picket line after unsuccessful contract negotiations.
- Production and maintenance employees refused to cross the office employees’ picket line, causing a work stoppage.
- Latrobe filed a federal action under § 301 of the Labor Management Relations Act seeking to enjoin the refusal to cross the picket line and to require use of the CBA’s grievance-arbitration process.
- After a same-day hearing, the district court issued a preliminary injunction prohibiting work stoppages and directing the parties to use the grievance-arbitration mechanism.
- Although union officers urged compliance and work briefly resumed, mass picketing later prevented production employees from entering the plant on additional days.
- The district court held the union in civil contempt and imposed coercive fines payable to the United States: $10,000 if employees did not report for the next shift, plus $10,000 per day for continued noncompliance.
- The union appealed the preliminary injunction and the contempt decree.

## Issues

1. Whether a federal district court has jurisdiction under § 301, consistent with the Norris–LaGuardia Act, to enjoin employees from refusing to cross a “stranger picket line” when the work stoppage is a sympathy action rather than a dispute arising under their own CBA.
2. If the injunction was improperly issued, whether a coercive civil contempt decree based on violation of that injunction may stand.

## Decision

- The court of appeals vacated the preliminary injunction.
- Applying intervening Supreme Court authority, the court held the district court lacked jurisdiction to enjoin the sympathy work stoppage because it was not over an arbitrable dispute between Latrobe and the production-and-maintenance bargaining unit.
- The court of appeals also vacated the coercive civil contempt judgment because it was designed to compel compliance with an injunction that was invalid for lack of jurisdiction.

## Legal Principles

- The Norris–LaGuardia Act generally bars federal labor injunctions; a limited § 301 exception permits injunctions only when necessary to enforce an agreement to arbitrate an underlying arbitrable dispute.
- A sympathy refusal to cross a “stranger picket line” is not rendered arbitrable merely because a CBA contains a broad no-strike clause and a broad grievance-arbitration provision; courts must identify an arbitrable underlying dispute between the employer and the enjoined employees.
- A coercive civil contempt sanction intended to force compliance with an injunction must be vacated when the underlying injunction is set aside as beyond the court’s jurisdiction.

## Conclusion

The Third Circuit held that federal courts could not enjoin this sympathy refusal to cross a stranger picket line because the dispute was not arbitrable under the production employees’ CBA, and it vacated both the injunction and the coercive contempt fines dependent on that invalid order.


Latrobe Steel Co. v. United Steelworkers of Am., 545 F.2d 1336 (3d Cir. 1976)