602 U.S. 339
SCOTUS2024Background
- Several Starbucks employees at a Memphis location announced plans to unionize and invited a TV crew to their store after hours to publicize the effort.
- Starbucks fired multiple employees involved in the media event for alleged violations of company policy.
- The National Labor Relations Board (NLRB) filed a complaint alleging unfair labor practices by Starbucks.
- The Board's regional Director sought a preliminary injunction under §10(j) of the National Labor Relations Act (NLRA) to reinstate the fired employees while the Board's administrative proceedings were pending.
- The District Court, applying the Sixth Circuit's two-part reasonable-cause test, granted the injunction; the Sixth Circuit affirmed.
- The Supreme Court granted certiorari to resolve a circuit split over whether the traditional four-factor test for preliminary injunctions (from Winter v. NRDC) or a more deferential reasonable-cause standard applies to §10(j) requests.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| What is the correct standard for §10(j) injunctions? | Board: Reasonable-cause test, deferential | Starbucks: Apply traditional four-factor | District courts must apply the traditional four-factor test (from Winter). |
| Congressional intent and statutory context | Board: Context requires deference | Starbucks: No clear displacement of equity | Statutory context does not displace or lower traditional equity principles. |
| District court's role vs. Board's authority | Board: District courts should not decide merits | Starbucks: District courts apply Winter | District courts can assess all Winter factors without infringing on Board’s authority. |
| Deference to Board’s preliminary position | Board: Some deference warranted | Starbucks: Only Board’s final decisions | District courts owe no special deference to Board’s preliminary litigation position. |
Key Cases Cited
- Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (U.S. 2008) (sets forth traditional four-factor test for preliminary injunctions)
- Hecht Co. v. Bowles, 321 U.S. 321 (U.S. 1944) (discusses when statutes displace traditional equitable principles)
- Weinberger v. Romero-Barcelo, 456 U.S. 305 (U.S. 1982) (discusses presumption in favor of traditional equity rules)
- United States v. Oakland Cannabis Buyers’ Cooperative, 532 U.S. 483 (U.S. 2001) (statutes do not lightly displace equity standards)