Burlington Northern Railroad Company v. Brotherhood of Maintenance of Way Employes (1986)
- Docket
- 86-39
- Decided
- 1986-01-01
Summary
Question: Does the Norris-LaGuardia Act allow federal courts to issue an injunction on labor dispute activities that do not involve the primary actors? Conclusion: No. Justice William J. Brennan, Jr. delivered the unanimous opinion of the Court. The Court held that Congress passed the Norris-LaGuardia Act expressly to prevent courts from distinguishing between primary and secondary actors for the purposes of labor immunity in labor disputes. Additionally, since Congress did not provide any clear way to distinguish between primary and secondary actors in such cases, the federal courts do not have jurisdiction to make decisions based on a distinction that lacks a legislative basis. The Court also held that Congress meant the term “labor dispute” to be broad, so the Norris-LaGuardia Act does not only refer to employers who are substantially aligned with the primary employer.