The U.S. Supreme Court unanimously sided with Starbucks in a challenge to a lower court ruling that tried to force the coffee chain to rehire employees fired for actions taken during their attempt to unionize. The decision marks a major defeat for the federal agency backing the former employees.
The entire legal saga started in 2022 after several Memphis-based Starbucks employees announced plans to unionize, at which point they “invited a news crew from a local television station to visit the store after hours to promote their unionizing effort.” Starbucks argued these actions violated company policy and fired the workers in response.
This prompted the National Labor Relations Board (NLRB), a federal agency that oversees labor disputes, to file an administrative complaint on behalf of the fired employees against the coffee chain alleging it had “engaged in unfair labor practices.” NLRB’s regional director subsequently filed a legal motion under the National Labor Relations Act requesting the U.S. District Court for the Western District of Tennessee implement a preliminary injunction “for the duration of the administrative proceedings that would, among other things, require Starbucks to reinstate the fired employees.”
When considering the motion, the district court utilized a two-part test to determine whether the NLRB was entitled to file such a petition, namely whether “there is reasonable cause to believe that unfair labor practices have occurred,” and if injunctive relief is “just and proper.” The district court ultimately granted the petition for injunction, which the Sixth Circuit Court of Appeals later upheld.
Writing for the majority, Associate Justice Clarence Thomas noted how some courts “instead apply the four-part test for preliminary injunctions articulated in Winter v. Natural Resources Defense Council, Inc.,” which mandates a plaintiff demonstrate “he is likely to succeed on the merits, that he is likely to suffer irreparable harm in the absence of preliminary relief, that the balance of equities tips in his favor, and that an injunction is in the public interest.”
The question before SCOTUS, he wrote, is over “what standard governs the Board’s requests for preliminary injunctions.”
Ruling against the NLRB, Thomas noted how “nothing” in the National Labor Relations Act (NLRA) “overcomes the presumption that the four traditional criteria” prescribed by federal law and affirmed in Winter “govern a preliminary injunction request by the Board.” He also criticized the district court for discarding such criteria in its granting of the NLRB’s petition for a preliminary injunction.
“Section 10(j) [of the NLRA] authorizes a district court ‘to grant to the Board such temporary relief … as it deems just and proper,’” Thomas wrote. “We do not understand the statutory directive to grant relief when the district court ‘deems’ it ‘just and proper’ to jettison the normal equitable rules. To the contrary, the phrase ‘just and proper’ invokes the discretion that courts have traditionally exercised when faced with requests for equitable relief.”
As such, SCOTUS vacated the Sixth Circuit’s ruling and remanded the case back to the district court. The district court “must apply the traditional four factors articulated in Winter when considering the Board’s requests for a preliminary injunction” under the NLRA, according to Thomas.
Associate Justice Ketanji Brown Jackson concurred with the court’s judgement but also filed a separate opinion concurring and dissenting in part. According to Reuters, Jackson disagreed with her colleagues on “how the lower court should apply part of [the four-factor] test.”
NLRB previously tried to sanction The Federalist over a tweet from one of its employees, but a federal court slapped the agency down and defended the right of The Federalist and its writers to tweet their opinions about major political issues, including labor policy.
Shawn Fleetwood is a staff writer for The Federalist and a graduate of the University of Mary Washington. He previously served as a state content writer for Convention of States Action and his work has been featured in numerous outlets, including RealClearPolitics, RealClearHealth, and Conservative Review. Follow him on Twitter @ShawnFleetwood
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