Labor Law: The Availability of Federal Injunctive Relief to Halt Sympathy Strikes

Abstract

INTRODUCTION|The Eighth Circuit Court of Appeals in Valmac Industries, Inc. v. Food Handlers Local 425, and the Second Circuit in Buffalo Forge Co. v. United Steelworkers reached opposite conclusions as to whether a federal court can enjoin a strike when the work stoppage is in sympathy with another bargaining unit and not the result of an independent contract dispute. Buffalo Forge and Valmac are factually similar. One segment of the employers' union work force went on strike over contract disputes. Picket lines were established and honored by other workers employed under separate and distinct bargaining agreements providing for arbitration and no-strike pledges. The employers requested injunctive relief to halt the sympathetic work stoppages which were in ostensible violation of the no-strike clauses. Both requests were predicated on Section 301 of the Labor-Management Relations Act which gives federal courts jurisdiction over labor disputes...