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San Diego Building Trades Council v. Garmon
United States Supreme Court
359 U.S. 236 (1959)
The San Diego Building Trades Council and other unions (defendants) sought an agreement requiring a lumberyard business to employ only union members. Garmon and other partners (plaintiffs) in the business refused, claiming none of its employees wanted to join a union. The unions peacefully picketed the lumberyard and advocated a boycott. The partners sued in California state court for an injunction and damages. The court found that the union picketed and promoted a boycott solely to pressure the partners to sign the agreement, enjoined those activities until the employees chose a collective-bargaining agent, and awarded the partners $1,000 in damages. But the Supreme Court reversed, reasoning that the injunction conflicted with National Labor Relations Board (NLRB) authority to issue cease-and-desist orders. On remand, the California court nonetheless sustained the damages award. The Supreme Court granted a second review to determine if the state court had jurisdiction to award damages for peaceful union activities it could not enjoin.
Rule of Law
Holding and Reasoning (Frankfurter, J.)
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