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Marine Cooks & Stewards, AFL, et al. v. Panama Steamship Co., Ltd., et al.

Supreme Court of United States
362 U.S. 365 (1960)
ELI5:

Rule of Law:

The Norris-LaGuardia Act's prohibition on federal courts issuing injunctions in cases involving a "labor dispute" applies to the peaceful picketing of a foreign-flagged vessel by an American union in a U.S. port to protest the loss of American jobs to ships with substandard labor conditions.


Facts:

  • The S.S. Nikolos, a vessel registered in Liberia and owned and chartered by Liberian corporations, employed an entirely alien crew under contracts made outside the United States.
  • There was no labor dispute between the crew of the Nikolos and the vessel's operators.
  • After the Nikolos arrived in Tacoma, Washington, with a cargo of salt, the petitioner union, Marine Cooks & Stewards, AFL, began to picket it.
  • The union, which represents American seamen, used a picket boat with signs protesting the loss of American jobs to foreign flagships with "substandard wages or substandard conditions."
  • The union peacefully circled the Nikolos and threatened to picket the cargo's consignee if any attempt was made to unload the ship.
  • As a result of the picketing, the Nikolos was unable to berth and deliver its cargo.

Procedural Posture:

  • The owner, time charterer, and master of the S.S. Nikolos (respondents) sued the Marine Cooks & Stewards union (petitioner) in a United States District Court, seeking an injunction and damages.
  • The District Court issued a temporary injunction restraining the union from picketing the vessel.
  • The District Court concluded that the case did not involve a 'labor dispute' under the Norris-LaGuardia Act and that the picketing was an unlawful interference with foreign commerce.
  • The union (petitioner) appealed the issuance of the injunction to the United States Court of Appeals for the Ninth Circuit.
  • The Court of Appeals affirmed the District Court's decision, upholding the injunction.
  • The United States Supreme Court granted certiorari to review the judgment of the Court of Appeals.

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Issue:

Does the Norris-LaGuardia Act deprive a United States District Court of jurisdiction to issue an injunction against an American union's peaceful picketing of a foreign-flagged vessel temporarily in a U.S. port?


Opinions:

Majority - Mr. Justice Black

No. The Norris-LaGuardia Act deprives the District Court of jurisdiction to issue the injunction. The controversy is a 'labor dispute' within the broad meaning of the Act because it concerns 'terms or conditions of employment' and involves persons in the same industry, regardless of whether they stand in the proximate relation of employer and employee. The Act was passed with the specific intent of removing federal courts from the 'labor injunction business,' and its jurisdictional limitations cannot be circumvented by labeling the picketing an 'unlawful interference with foreign commerce' or an interference 'in the internal economy' of a foreign vessel. The Court's prior decision in Benz v. Compania Naviera Hidalgo is distinguishable because it concerned the scope of the Labor Management Relations Act and state law damages, not the jurisdictional bar of the Norris-LaGuardia Act on federal injunctions. When a foreign ship voluntarily enters U.S. territorial waters, it subjects itself to U.S. laws, including the Norris-LaGuardia Act's restrictions on federal court jurisdiction.


Dissenting - Mr. Justice Whittaker

Yes. The District Court was not deprived of jurisdiction to issue the injunction. The controversy does not constitute a lawful 'labor dispute' within the meaning of the Norris-LaGuardia Act.



Analysis:

This decision significantly reaffirms the broad scope of the Norris-LaGuardia Act's anti-injunction provisions. It clarifies that the definition of a "labor dispute" is not confined to direct employer-employee conflicts but extends to protests over economic competition from foreign labor, which unions argue undermines domestic labor standards. By applying the Act to disputes involving foreign vessels in U.S. waters, the Court prevents a major potential exception from being carved out of the statute's jurisdictional bar. The ruling strengthens the position of American unions in protesting the use of 'flags of convenience' ships and ensures that federal courts remain largely outside the business of issuing labor injunctions, as Congress intended.

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