Defendant union struck the Florida East Coast Railroad in a dispute over work rules, and began picketing plaintiff railroad terminal company which serviced the Florida East Coast and other railroads. Defendant's picketing was designed to stop plaintiff from servicing trains of the struck railroad which were being operated by replacement crews. The district court, holding the Norris-LaGuardia Act inapplicable, enjoined the picketing on the theory that it interfered with obligations owed by plaintiff terminal company to the railroad arising from an agreement, a previous injunction, and the Interstate Commerce Act. On appeal, the Fifth Circuit Court of Appeals reversed. Held: The scope of the Norris-LaGuardia Act is determined by "traditional economic self-interest justification concepts" which forbid enjoining a secondary boycott when the union has an economic interest in the activities of the secondary employer because of his relationship with the primary employer. Brotherhood of Railroad Trainmen v. Atlantic Coast Line R.R., 362 F.2d 649 (5th Cir.), aff'd per curiam by equally divided court, 385 U.S. 20 (1966).
Railroad Secondary Boycotts: Railway Labor Act Versus Norris-LaGuardia,
Wash. L. & Rev.
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