BAKER ET AL. v. GENERAL MOTORS CORP. ET AL.
No. 85-117
Supreme Court of the United States
Argued April 2, 1986—Decided July 2, 1986
478 U.S. 621
Jordan Rossen argued the cause for appellants. With him on the briefs was Fred Altshuler.
Peter G. Nash argued the cause for appellees. With him on the brief were Dixie L. Atwater, J. R. Wheatley, and Jonathan N. Wayman.
Deputy Solicitor General Cohen argued the cause for the United States as amicus curiae urging affirmance. On the brief were Solicitor General Fried, Deputy Solicitor General Kuhl, Jerrold J. Ganzfried, Norton J. Come, and Linda Sher.
JUSTICE STEVENS delivered the opinion of the Court.
In Michigan an employee is ineligible for unemployment compensation if he has provided “financing“—by means other than the payment of regular union dues—for a strike that causes his unemployment.1 The question presented by this
This case has a long history. Two appeals to the State Supreme Court and a series of administrative proceedings have determined the relevant facts and the meaning of the governing statutory provision. Before addressing the federal question, we shall therefore summarize the events that gave rise to the controversy and the propositions of state law that were resolved on each appeal.
The Relevant Events
The story begins in June 1967, when the international union3 representing the work force in the automobile industry notified the three major manufacturers—General Motors, Ford, and Chrysler—that it intended to terminate all national and local collective-bargaining agreements when they expired on September 6, 1967. In August, after the UAW
On October 8, 1967, while the Ford strike was continuing,4 the UAW held a special convention to authorize “adequate strike funds to meet the challenges of the 1967 and 1968 collective bargaining effort.”5 At that convention the UAW amended its constitution to authorize the collection of “emergency dues”6 that would be used to augment the Union‘s
“These emergency extra dues are being raised to protect GM workers as well as support the Ford strikers. When our time comes at GM, we cannot go back to the bargaining table without an adequate strike fund behind us and promise of continued assistance from other UAW members.” 420 Mich. 463, 513, 363 N. W. 2d 602, 624-625 (1984) (footnote omitted).
The emergency dues were payable immediately and were to remain in effect during the “collective bargaining emergency.” See n. 6, supra. They were much larger than the regular dues. Before the emergency, each UAW member paid strike insurance dues of $1.25 per month and administrative dues of $3.75. The amendment increased the contribution to the strike insurance fund to $21.25 per month for employees in plants where the average straight-time hourly earnings amounted to $3 or more, and to $11.25 in plants where the average earnings were lower. Thus, for the former group the increase of $20 was 16 times as large as the regular contribution to the strike fund; for the latter group the $10 increase was 8 times as large.
The strike against Ford was settled in October, before the first scheduled collection of the new special strike fund dues. Notwithstanding this development, emergency dues of $42 million were subsequently collected until November 30, 1967—when the UAW determined that it would not strike any GM plants “at least during the month of December 1967.”7 At this point the UAW advised its membership that
In January 1968, however, three UAW local unions went on strike at three GM foundries for periods of 10, 11, and 12 days.8 Strike fund benefits of $4 to $6 a day, totaling $247,245.31, were paid to the striking UAW employees from the fund in which the emergency dues collected in October and November had been deposited. At that time the emergency dues constituted about half of the money in the fund.9 As a result of the strikes, operations were temporarily curtailed at 24 other functionally integrated GM plants, idling more than 19,000 employees. Most of these employees are appellants in this case. Their claims for unemployment benefits were considered at three levels of administrative review10 and three levels of judicial review,11 and were ultimately denied by the State Supreme Court.
In its first opinion in this case the Michigan Supreme Court decided two statutory questions and remanded a third for further consideration by the Board of Review.
It first held that appellants’ unemployment was “due to a labor dispute in active progress” at other establishments operated by the same employing unit and functionally integrated with the establishments where appellants were employed within the meaning of the statute. It rejected the argument that the layoffs were due not only to the strikes, but also to a combination of management decisions and seniority provisions in the collective-bargaining agreement, holding instead that the strikes were a “substantial contributing cause” of the unemployment and need not be its sole cause.12
After finding the requisite causal connection between the strikes and the layoffs, the court considered the relationship between the emergency dues and the strikes. Appellants contended that their payments were expressly excepted from the coverage of the statute because they were “regular union dues.” The State Supreme Court rejected this argument, explaining that the term “regular” had been used “to exclude from possible treatment as financing those dues payments re-
The court did not decide whether the emergency dues constituted “financing” of the local strikes. It noted that the statute did not require that the payments made by the individuals whose disqualification was in issue must be traced into the hands of the striking employees, but it indicated that there must be a “meaningful connection” between the payments and the strikes to satisfy the “financing” requirement. It therefore remanded the case to the Appeal Board‘s successor tribunal to consider that question.15
The Second Appeal
On remand, the Board of Review concluded that there was a “meaningful connection” between the emergency dues and the GM strikes. It found that the dues were intended to support local strikes at GM plants, that strikes which might affect their own employment were foreseeable at the time appellants paid the emergency dues, and that the dues were a substantial source of funding for the strikes. The Supreme Court agreed.
As a predicate to its analysis, the court explained that the term “financing” should be construed in the light of the general purpose of the statute to provide assistance to persons
The Michigan Supreme Court considered and rejected appellants’ argument that their emergency dues payments were not voluntary because they were required by the UAW in order to retain their union membership and their jobs at GM. The court held that employees could not use their own collective-bargaining agent as a shield to protect them from responsibility for conduct that they had authorized. It therefore specifically held that appellants’ “emergency dues payments were not involuntary.”18
Only after it had meticulously satisfied itself that the emergency dues payments constituted “financing” that made appellants ineligible for unemployment compensation under the Michigan statute, did the court turn to the question whether its construction of state law was pre-empted by federal law because it inhibited the exercise of rights guaranteed by the National Labor Relations Act (NLRA). The state court agreed with appellants that the right to support strikes by paying extraordinary dues was protected by § 7 of the NLRA, but concluded that the legislative history of the Social Security Act which was reviewed in New York Telephone Co. v. New York State Dept. of Labor, 440 U.S. 519 (1979),
We noted probable jurisdiction of their appeal, 474 U. S. 899 (1985), and now affirm. We first discuss the problem presented by the case in general terms and then consider the specific contentions that appellants advance.
I
The National Labor Relations Act and the Social Security Act were both enacted in the summer of 1935. See New York Telephone Co. v. New York State Dept. of Labor, 440 U. S., at 527. Neither statute required any State to adopt, or to maintain, an unemployment compensation program. See Steward Machine Co. v. Davis, 301 U. S. 548, 596 (1937). Title IX of the latter Act did, however, motivate the enactment of state programs throughout the Nation.25 That Title authorized the provision of federal funds to States having
The policy of allowing “broad freedom to set up the type of unemployment compensation they wish” has been a basic theme of the program since the general outlines of the legislation were first identified in the Report of the Committee on Economic Security that was prepared for “the President of the United States and became the cornerstone of the Social Security Act.” Ohio Bureau of Employment Services v. Hodory, 431 U. S. 471, 482 (1977). In guiding state efforts to draft unemployment compensation programs, however, that Report also stressed the importance of the distinction between voluntary and involuntary unemployment. It characterized that distinction as “the key to eligibility.” Id., at 483. “To serve its purposes, unemployment compensation must be paid only to workers involuntarily unemployed.” Id., at 482 (quoting Report of the Committee on Economic Security, as reprinted in Hearings on S. 1130 before the Senate Committee on Finance, 74th Cong., 1st Sess., 1311, 1328 (1935)).
The involuntary character of the unemployment is thus generally a necessary condition to eligibility for compensation. But even involuntary unemployment is not always a sufficient condition to qualify for benefits, as we found in Hodory. In that case, we held that Ohio could disqualify a millwright who was furloughed when the plant where he worked was shut down because of a shortage of fuel caused by a strike at coal mines owned by his employer. Even though he was unemployed through no fault of his own, as the result of a labor dispute in which he had no interest, federal law did not require Ohio to pay him unemployment compensation.
In Hodory there was no claim that the National Labor Relations Act pre-empted Ohio‘s disqualification of unemploy-
“Undeniably, Congress was aware of the possible impact of unemployment compensation on the bargaining process. The omission of any direction concerning payment to strikers in either the National Labor Relations Act or the Social Security Act implies that Congress intended that the States be free to authorize, or to prohibit, such payments.” Id., at 544.
See id., at 547 (BRENNAN, J., concurring in result); id., at 549 (BLACKMUN, J., with whom MARSHALL, J., joined, concurring in judgment).
Our conclusion that Congress did not intend to pre-empt the States’ power to make the policy choice between paying or denying unemployment compensation to strikers does not directly respond to the argument advanced by appellants in this case. For they rely, not on the general policy of non-
Thus, New York Telephone Co. makes it clear that a State may, but need not, compensate actual strikers even though they are plainly responsible for their own unemployment. And, on the other hand, Hodory makes it equally clear that a State may refuse, or provide, compensation to workers laid off by reason of a labor dispute in which they have no interest or responsibility whatsoever. In between these opposite ends of the spectrum are cases in which the furloughed employees have had some participation in the labor dispute that caused their unemployment. This is such a case, because the state court has found that appellants provided significant financial support to strikes against their employer with full knowledge that their own work might thereby suffer. It is clear, however, that in financing the local strikes, they were exercising associational rights that are expressly protected by § 7 of the NLRA. The question, then, is whether that protection deprives the State of the power to make the policy choice that otherwise would be plainly authorized by Title IX of the Social Security Act.
II
Appellants place their primary reliance on Nash v. Florida Industrial Comm‘n, 389 U. S. 235 (1967), a case in which the Florida Commission had concluded that a union member was disqualified for unemployment compensation because she had filed an unfair labor practice charge against her employer. The Florida District Court of Appeal held that the Commis-
“[C]oercive actions which the Act forbids employers and unions to take against persons making charges are likewise prohibited from being taken by the States. . . . Florida should not be permitted to defeat or handicap a valid national objective by threatening to withdraw state benefits from persons simply because they cooperate with the Government‘s constitutional plan.” Id., at 239.
The federal right implicated in Nash was the right to file an unfair labor practice charge with the Board. Arguably there are two different rights protected by § 7 that are implicated by this case—the right to contribute to a fund that will strengthen the union‘s bargaining position, and the right to expend money to support a strike. It would seem clear that it would be an unfair labor practice for an employer to discharge an employee for making a contribution to a strike fund or for voting in favor of a strike at another plant, just as it would be unlawful to discharge an employee for filing a charge with the Labor Board. In each such case, the unemployment would be attributable to an unlawful act by the employer rather than the foreseeable consequence of the exercise of the employee‘s § 7 rights.
In the actual case before us, however, the employer did nothing to impair the exercise of appellants’ § 7 rights. To the extent that appellants may be viewed as participants in the decision to strike, or to expend funds in support of the
Perhaps the answer is less obvious when we focus on the payment of the emergency dues before any actual strike decision has been made, but we believe similar reasoning leads to the same conclusion. Appellants were not laid off simply because they paid emergency dues. Rather, under the meticulous analysis of the case by the Michigan Supreme Court, they became unemployed because there was a meaningful connection between the decision to pay the emergency dues, the strikes which ensued, and ultimately their own layoffs. Under the state court‘s narrow construction of its own statute, the emergency dues decision was tantamount to a plant-wide decision to call a strike in a bottleneck department that would predictably shut down an entire plant. As the court put it, “since the Michigan law only disqualifies those who are directly involved in the labor dispute through financing, the MESA essentially only disqualifies ‘strikers.‘” 420 Mich., at 540, 363 N. W. 2d, at 637. Unquestionably federal law protects the employees’ right to authorize such a strike; it is equally clear, however, that federal law does not prohibit the States from deciding whether or not to compensate the employees who thereby cause their own unemployment. New York Telephone Co., 440 U. S., at 540-546.
Thus, the essential distinction between the Nash case and this one is the distinction between involuntary and voluntary unemployment that was recognized at the inception of the Social Security Act. A decision to file an unfair labor practice charge—even though it may in fact motivate a retaliatory discharge—cannot be treated as a voluntary decision to cause
In reaching this conclusion, we of course express no opinion concerning the wisdom of one policy choice or another. Nor are we concerned with the possible application of the “financing” disqualification that has been adopted in numerous States other than Michigan and which, like the Florida statute involved in Nash, may be construed in a way that has an entirely different impact on § 7 rights. Specifically, we have no occasion to consider the circumstances, if any, in which individuals might be disqualified solely because they paid regular union dues required as a condition of their employment.26 We merely hold that the “financing” disqualification in the Michigan statute as construed by the State Supreme Court in this case is not pre-empted by federal law.
Affirmed.
JUSTICE BRENNAN, with whom JUSTICE MARSHALL and JUSTICE BLACKMUN join, dissenting.
The State of Michigan disqualifies an individual from receiving unemployment benefits for “financing” the labor dispute that causes his unemployment.
In enacting Title IX of the Social Security Act, Congress left the States a “wide range” of discretion to establish qualifications for receiving unemployment benefits. Steward Machine Co. v. Davis, 301 U. S. 548, 593 (1937); see also Ohio Bureau of Employment Services v. Hodory, 431 U. S. 471, 482-489 (1977). We have previously found evidence in the legislative history of the Social Security Act indicating that Congress intended that this broad grant of authority should include power to authorize or deny unemployment benefits in ways that may interfere with the smooth operation of the federal labor laws. Thus, in New York Telephone Co. v. New York State Dept. of Labor, 440 U. S. 519 (1979), we held that the States were free to authorize or to prohibit payment of unemployment benefits to striking workers notwithstanding the impact of such payments on the collective-bargaining process. We based our conclusion on evidence in the legislative history of the Social Security Act specifically indicating that Congress intended to leave the States such authority. Id., at 540-546 (plurality opinion); see also, id., at 546-547 (BRENNAN, J., concurring in result); id., at 549 (BLACKMUN, J., concurring in judgment).
It is clear, however, that the States’ discretion to fashion qualifications for unemployment compensation is not boundless, and that state laws that conflict with the NLRA in ways
“The action of Florida here, like the coercive actions which employers and unions are forbidden to engage in, has a direct tendency to frustrate the purpose of Congress to leave people free to make charges of unfair labor practices to the Board. . . . It appears obvious to us that this financial burden which Florida imposes will impede resort to the Act and thwart congressional reliance on individual action. A national system for the implementation of this country‘s labor policies is not so dependent on state law. Florida should not be permitted to defeat or handicap a valid national objective by threatening to withdraw state benefits from persons simply because they cooperate with the Government‘s constitutional plan.” Id., at 239 (footnote omitted).
As the Court recognizes, ante, at 635, a “financing” disqualification such as Michigan‘s implicates important rights that are protected by § 7 of the NLRA. In particular, such a disqualification may prevent workers from exercising their right to expend money in support of a strike, and, more generally, it will influence their willingness to contribute to a fund that will strengthen the union‘s position in collective bargaining. The question we must answer in this case, then, is whether—as in New York Telephone Co.—there is reason to think that Congress intended to tolerate the conflict between Michigan‘s “financing” provision and the NLRA, or
I note at the outset that it is highly unusual to interpret one law by reference to the legislative history of a different law. However, because the NLRA and the Social Security Act were considered by Congress at the same time and were passed within five weeks of one another, it is sometimes appropriate to read them in pari materia. See New York Telephone Co., supra, at 540-541; ante, at 632-633. Nonetheless, the NLRA and the Social Security Act are distinct pieces of legislation that address very different concerns. Consequently, we cannot find that Congress intended to withdraw protections extended in the NLRA on the basis of the legislative history of the Social Security Act unless the expression of Congress’ intent to do so is especially clear. In this case, the available evidence is anything but clear in support of the conclusion that Congress intended to permit States to deny unemployment benefits to individuals for “financing” a labor dispute in the manner approved by the Michigan Supreme Court. Unlike the discussion in the legislative history concerning unemployment benefits for actual strikers that was relied upon in New York Telephone Co., supra, at 542-544, there is no comparable discussion at any point in the legislative history of benefits for individuals who “finance” a labor dispute. Nor does the Report of the Committee on Economic Security, which “became the cornerstone of the Social Security Act,” ante, at 633 (quoting Ohio Bureau of Employment Services v. Hodory, supra, at 482), mention the subject of a “financing” disqualification. The sole support for the use of a financing disqualification is in “draft bills” prepared by the Social Security Board one year after the Social Security Act was passed as examples of what the Act permitted the States to do. These draft bills disqualified workers from receiving benefits if their unemployment was due to a labor dispute which they were “participating in or financing or directly interested in . . . .” United States
One could argue that, in light of this scant legislative history, there is no basis for concluding that Congress intended to authorize the States to utilize any kind of “financing” disqualification that interferes with rights protected by the NLRA. However, because the draft bills constitute a contemporaneous construction of an Act by those charged with the responsibility for setting it in motion, they are entitled to considerable deference. See Udall v. Tallman, 380 U. S. 1, 16 (1965) (quoting Power Reactor Development Co. v. Electrical Workers, 367 U. S. 396, 408 (1961)). We may therefore conclude that the States may enact some sort of “financing” disqualification even though this might conflict with the NLRA. The difficult question is what kind.
Unfortunately, the Social Security Board did not elaborate on its understanding of the permissible scope of its financing disqualification, so there is nothing in the draft bills from which to determine how broad the disqualification may be, consistent with the NLRA. It is at least clear, however, that the Social Security Board thought that there were limits on the scope of any financing disqualification. For within just a few years, the Board deleted this disqualification from its draft bills, explaining:
“The provision found in some laws extending the disqualification to individuals who are financing a labor dispute is not recommended since it might operate to disqualify an individual not concerned with the dispute solely on the basis of his payment of dues to the union that is conducting the strike.” United States Social Security Board, Bureau of Employment Security, Proposed State Legislation Providing for Unemployment Compensation and Public Employment Offices, Employment Security Memorandum No. 13, p. 56, note (Nov. 1940).
Where this is true, i. e., where workers agree to pay special dues1 to finance a particular labor dispute that they
know will result in their own layoffs, they voluntarily cause their own unemployment in the same sense as actual strikers. Therefore, I agree with the Court that “[t]o the extent that appellants may be viewed as participants in the decision to strike, or to expend funds in support of the local strikes, it is difficult to see how such a decision would be entitled to any greater protection than is afforded to actual strikers.” Ante, at 636-637. I also agree with the Court that, insofar as “the emergency dues decision was tantamount to a plantwide decision to call a strike in a bottleneck department that would predictably shut down an entire plant,” ante, at 637, Michigan could disqualify workers who paid the dues. In other words, to the extent that Michigan denies benefits to workers who agree to pay special dues to finance the very strike
As interpreted by the Michigan Supreme Court, however, the Michigan statute also denies benefits to individuals whose unemployment results from a labor dispute financed with money raised for a different labor dispute—so long as the dispute that caused the unemployment was “foreseeable” at the time the contribution was made. Michigan‘s law thus denies benefits to an individual for “financing” a labor dispute even though he did not necessarily intend to finance that dispute. Yet, where this is the case, the disqualification cannot be justified as necessary to effectuate the disqualification of actual strikers. Therefore, to the extent that it interferes with rights protected by the NLRA, it is pre-empted. Moreover, in my view, an individual who did not intend to finance the labor dispute that led to his being laid off cannot be said to have “voluntarily” caused his own unemployment in the same sense as a striker; the Court‘s unexplained equation of the two is simply wrong.
Finally, denying benefits to an individual who paid special dues merely because the strike that caused his unemployment was foreseeable when the decision to pay the dues was made interferes with rights protected by the NLRA in a much more pervasive manner than a disqualification of actual strikers. Consider the decision that must be made by a union member asked to vote on whether to collect special dues to finance an anticipated strike. If he agrees to pay the special dues and the strike results in his being laid off, he will not receive unemployment benefits under state law. This possibility will certainly influence his decision whether or not to vote in favor of the special dues, and, to that extent, the state law conflicts with a federally protected right. However, as explained above, because the union member‘s decision in this regard is essentially identical to the decision of an actual striker, I agree with the Court that it is reasonable to conclude that Congress was willing to tolerate this conflict.
Because of its construction of the Michigan statute, the Michigan Supreme Court did not find it necessary to consider whether the local foundry strikes were expressly contemplated by the UAW in its decision to collect the emergency dues. Accordingly, I would vacate the judgment below and remand the case to the Michigan Supreme Court to consider this question.
Notes
Section 29(8) of the Michigan Employment Security Act (MESA) provides:
“(8) An individual shall be disqualified for benefits for a week in which the individual‘s total or partial unemployment is due to a labor dispute in active progress in the establishment in which the individual is or was last employed, or to a labor dispute, other than a lockout, in active progress . . . in any other establishment within the United States which is functionally integrated with the establishment and is operated by the same employing unit. . . . An individual shall not be disqualified under this subsection if the individual is not directly involved in the dispute.
“(a) For the purposes of this subsection an individual shall not be considered to be directly involved in a labor dispute unless it is established that any of the following occurred:
. . . . .
“(ii) The individual is participating in or financing or directly interested in the labor dispute which causes the individual‘s total or partial unemployment. The payment of regular union dues, in amounts and for purposes established before the inception of the labor dispute, shall not be construed as financing a labor dispute within the meaning of this subparagraph.”
The Michigan statute provides that “[t]he payment of regular union dues, in amounts and for purposes established before the inception of the labor dispute, shall not be construed as financing a labor dispute . . . .”
Section 7 of the National Labor Relations Act, 49 Stat. 452,
“Employees shall have the right to self-organization, to form, join, or assist labor organizations, to bargain collectively through representatives of their own choosing, and to engage in other concerted activities for the purpose of collective bargaining or other mutual aid or protection. . . .”
This concern is somewhat alleviated under the Michigan statute by the additional requirement that the labor dispute which causes the unemployment occur “in temporal proximity” to the making of the financial contribution.The proceedings of the convention recited that its purposes were:
“1. [To] [r]eview the status of our 1967 collective bargaining effort.
“2. To consider revision of the dues program of the International Union, UAW, to provide adequate strike funds to meet the challenges of the 1967 and 1968 collective bargaining effort.
“3. To consider revisions of the Constitution of the International Union as it relates to the payment of dues, strike fund, membership eligibility, strike insurance program and other matters related to emergencies facing the International Union, UAW.” 420 Mich. 463, 512-513, 363 N. W. 2d 602, 624 (1984).
The text of the amendments reads, in pertinent part:
“Article 16, Section 2(a) (new): Emergency Dues
“All dues are payable during the current month to the financial secretary of the local union.
“Commencing with the eighth (8th) day of October 1967 until October 31, 1967, and for each month thereafter during the emergency as defined in the last paragraph of this subsection, union administrative dues shall be three dollars and seventy-five cents ($3.75) per month and Union Strike Insurance Fund dues shall be as follows:
“1. For those working in plants where the average straight time earnings * * * is three dollars ($3.00) or more, twenty-one dollars and twenty-five cents ($21.25) per month.
“2. For those working plants where the average straight time earnings * * * is less than three dollars ($3.00), eleven dollars and twenty-five cents ($11.25).
. . . . .
“This schedule of dues shall remain in effect during the current collective bargaining emergency as determined by the International Executive Board and thereafter, if necessary, until the International Union Strike Insurance Fund has reached the sum of twenty-five million dollars ($25,000,000). . . .” Id., at 472, 363 N. W. 2d, at 606.
“As noted above, the statute does not recognize such a ploy. UAW membership is required for employment by GM because the UAW bargains for such a provision in its contract with GM. In so doing, the UAW represents its members and they must ratify any contract agreed upon by the UAW and GM. Therefore, any ‘coercion’ resulting from the terms of the contract does not make the plaintiffs’ action in accord with the contract ‘involuntary.’ As the Court of Appeals said in Applegate v. Palladium Publishing Co., 95 Mich. App. 299, 305; 290 N. W. 2d 128 (1980), and we adopt here:
“‘Action taken by employees under a contract negotiated for them by their authorized agent must be considered their voluntary acts. In effect, plaintiff agreed to [act] pursuant to the collective bargaining agreement.’
“Any other holding would make all actions taken by union members pursuant to a union contract involuntary and relieve the members of responsibility for their contract-based actions. We cannot agree with such a rule. The plaintiffs’ emergency dues payments were not involuntary.” 420 Mich., at 499, 363 N. W. 2d, at 618-619.
“The final aspect of the purpose analysis focuses on whether it was foreseeable at the time of the financing that supporting the labor disputes would cause the claimant‘s unemployment. In this case, there is and can be no dispute on this issue. Since it was foreseeable that local GM strikes would occur and be financed by the emergency dues, and since automotive industry production is based upon a series of interrelated production units which produce only one component of the automobile, it is obvious that a local labor dispute which idles one plant might cause layoffs at other plants which rely upon the component produced at the idled plant. This ‘chain reaction’ can move both ‘up’ and ‘down’ the line. Therefore, layoffs at plants not presently engaged in a local labor dispute were foreseeable due to local disputes.
“In conclusion, the evidence adduced in this case supports the conclusion that the purpose of the emergency dues included supporting labor disputes including those that actually caused the plaintiffs’ unemployment. Therefore, the first portion of the meaningful connection definition is met.” Id., at 516-517, 363 N. W. 2d, at 626.