LABOR LAW--FEDERAL-STATE RELATIONS--VALIDITY OF MICHIGAN'S LABOR MEDIATION ACT

Plaintiff labor union called a strike against defendant auto corporation in May, 1948, without conforming to the prescribed state procedure. The purpose of the strike was to enforce demands for higher wages and the strike was conducted peacefully. To enjoin possible criminal prosecution the union instituted the instant suit in the state courts, contending that the Michigan labor mediation law, the much publicized "Bonine-Tripp Act," violated the due process and commerce clauses of the Federal Constitution. The Michigan Supreme Court reversed the decision of the trial court which had granted the injunction.

On appeal, held, reversed. Congress has occupied the field of regulation of peaceful strikes for higher wages, and has closed it to state regulation; and even if some state regulation in this area could be sustained, the particular statute involved could not stand because it conflicts with the over-riding federal act. U.A.W.-C.I.O. v. O'Brien, 339 U.S. 454, 70 S.Ct. 781 (1950).