## Facts

- A multiemployer collective bargaining agreement covering interstate motor carriers and Teamsters locals in 12 Midwestern states included Article XXXII regulating “owner-operators” who leased their trucks to carriers and personally drove them.
- Article XXXII set minimum truck-rental rates and lease terms applicable when the lessor also drove the vehicle.
- The agreement treated the owner-operator as an employee while driving: the carrier reserved control over the manner and details of the work; wages, hours, and working conditions matched those of drivers of carrier-owned trucks; seniority was “as a driver only.”
- The minimum rental provision was intended to prevent carriers from evading the negotiated wage scale by paying rentals too low to cover owner-operators’ operating costs, effectively reducing their net wages below the bargained-for level.
- Revel Oliver sued in Ohio state court to enjoin enforcement of the minimum rental provision under Ohio’s antitrust statute (the Valentine Act), and Ohio courts granted and affirmed an injunction, characterizing the clause as unlawful price-fixing.

## Issues

1. Whether a state may apply its antitrust law to enjoin enforcement of a collectively bargained minimum truck-rental provision aimed at protecting the negotiated wage scale.
2. Whether such a minimum rental clause falls within the subjects of bargaining required or protected by §§ 7 and 8 of the National Labor Relations Act.
3. Whether federal labor policy precludes state-law interference with implementing a collective bargaining agreement term that federal law directs parties to bargain about.

## Decision

- The Supreme Court reversed the Ohio judgments enjoining enforcement of Article XXXII’s minimum rental provision.
- The Court held that the minimum rental clause, adopted to protect the negotiated wage scale from erosion, was within the scope of collective bargaining required under the NLRA.
- Because federal law directs bargaining over such wage-related terms, Ohio could not apply its antitrust law to prevent the parties from carrying out their agreement.
- The Court rejected the view that the clause was merely a remote or indirect approach to wages; the rental rate directly affected whether owner-operators realized the bargained-for wage after operating costs.

## Legal Principles

- A collectively bargained provision setting minimum truck-rental payments to owner-operators, when used to protect the negotiated wage scale, is a permissible and mandatory subject of bargaining under §§ 7 and 8 of the NLRA.
- A state may not apply its antitrust law to bar implementation of an agreement term on a subject matter that federal labor law directs parties to bargain about.
- When a provision is integrated into the employment relationship (including employer control and standardized driver working conditions), it may be treated as wage-related even if it resembles commercial price regulation.

## Conclusion

The Court held that federal labor law precludes state antitrust enforcement against a collectively bargained minimum truck-rental provision designed to protect the negotiated wage scale, and it reversed Ohio’s injunction barring implementation of that agreement term.


Local 24, Int’l Bhd. of Teamsters, Chauffeurs, Warehousemen & Helpers of Am. v. Oliver, 358 U.S. 283 (1959)