Davis v. Henry

555 So. 2d 457 (1990)

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Davis v. Henry

Louisiana Supreme Court
555 So. 2d 457 (1990)

Facts

At common law, it was broadly considered unlawful and criminal for employees to strike collectively. A legal trend against this regime in America began around the early twentieth century. In 1932, as part of this trend, Congress passed the Norris LaGuardia Act, which limited the federal courts’ abilities to intervene in labor disputes, such as by issuing injunctions against strikes. Many states, including Louisiana in 1934, passed their own versions of the statute; these statutes became known as Little Norris-LaGuardia Acts. The text of Louisiana’s Little Norris-LaGuardia Act did not explicitly include public-sector employees within its scope. However, the majority of Louisiana court decisions for which such inclusion was at issue operated under the assumption that public employees were included. A group of teachers, bus drivers, cafeteria workers, and janitors of the Terrebonne Parish School Board, calling themselves members of the Terrebonne Parish Association of Educators (union) (plaintiff), went on strike, refusing to return to work until the school board (defendant) agreed to engage in collective bargaining. The strike became the longest in Louisiana history, and eventually the union filed an action in state court seeking both monetary and injunctive relief. The school board responded by seeking a declaration that the strike was illegal. The board also sought an injunction. The trial court held that Louisiana’s Little Norris-LaGuardia Act applied and found, accordingly, that the court lacked jurisdiction to grant relief to either party. The court of appeals reversed, holding that the school board was entitled to an injunction. The union appealed to the Louisiana Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Dixon, C.J.)

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