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Buffalo Forge Co. v. United Steelworkers of America

428 U.S. 397 (1976)

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Buffalo Forge Co. v. United Steelworkers of America

United States Supreme Court
428 U.S. 397 (1976)

  • Written by Tammy Boggs, JD

Facts

The Buffalo Forge Co. (plaintiff) had collective-bargaining agreements with two local unions of the United Steelworkers of America (the unions) (defendants). The unions represented production and maintenance workers at three Buffalo Forge plants. The collective-bargaining agreements contained no-strike clauses and grievance and arbitration provisions for settling disputes over contract interpretation. Separately, office workers at the three Buffalo Forge plants had been negotiating for months on collective-bargaining terms. The office workers went on strike, and consequently, in solidarity, the unions’ production and maintenance workers honored the office workers’ picket line and refused to work as well. Buffalo Forge filed a complaint in district court alleging that the unions had violated the no-strike clauses and prayed for injunctive relief. Arbitration on the contract dispute had not yet commenced. The district court found that the unions’ workers had gone on strike in “sympathy” rather than over their own grievance and the court was not authorized to issue an injunction under the Norris-LaGuardia Act. The court of appeals affirmed, and the Supreme Court agreed to review the matter.

Rule of Law

Issue

Holding and Reasoning (White, J.)

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