Enjoining Politically Motivated Strikes in Federal Courts: The Jacksonville Bulk Terminals Case

The United States Supreme Court, in Jacksonville Bulk Terminals, Inc. v. International Longshoremen's Association, acknowledged that a work stoppage entirely motivated by political goals constitutes a "labor dispute" within the Norris-La Guardia Act which is prohibited from injunctive relief by a federal court. In so ruling, the Supreme Court found the Boys Markets, Inc. v. Retail Clerks Union and Buffalo Forge Co. v. United Steelworkers of America, AFL-CIO exceptions, which allow an injunction to issue pending arbitration in situations where the dispute underlying the work stoppage is arbitrable, to be inapplicable to the no-strike clause in the collective-bargaining agreement scrutinized. The case represents a victory for labor while leaving the employer in the precarious position of having "bargained for" no-strike clauses which are ineffective. The author delineates the extent of labor's victory and presents the options available for management.