CARPENTERS DISTRICT COUNCIL OF JACKSONVILLE AND VICINITY, A LABOR ORGANIZATION, AND AS AN UNINCORPORATED ASSOCIATION, BY AND THROUGH JOHN H. SEA, BUSINESS REPRESENTATIVE THEREOF; AND CARPENTERS LOCAL UNION NO. 627, A LABOR ORGANIZATION, AND AS AN UNINCORPORATED ASSOCIATION, BY AND THROUGH EARL S. HUFF, ASSISTANT BUSINESS REPRESENTATIVE THEREOF, PETITIONERS,
v.
THE HONORABLE ROGER J. WAYBRIGHT, AS CIRCUIT JUDGE OF THE FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA, RESPONDENT
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
The Florida Supreme Court, on remand from the U.S. Supreme Court, considers whether state courts have jurisdiction to enjoin a strike that constitutes both a breach of a no-strike clause in a collective-bargaining agreement and an alleged unfair labor practice under federal law. The U.S. Supreme Court held that state courts retain jurisdiction to enforce collective-bargaining agreements even when the conduct also arguably violates federal labor law.
State courts have jurisdiction to enforce collective-bargaining agreements and enjoin strikes in violation of no-strike clauses, even when the strike also arguably constitutes an unfair labor practice under federal law. The Board's federal authority is not exclusive and does not destroy the jurisdiction of courts in suits under § 301 of the Labor Management Relations Act.
[1] State courts have jurisdiction to enforce collective-bargaining agreements and enjoin strikes in violation of a no-strike clause, even when the strike is also arguably an…
[2] A court's authority to grant injunctive relief for a breach of a collective-bargaining agreement is not exclusive and does not preclude jurisdiction of the courts in suit…
Previewing 2 of 3 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“It is unquestionable that state courts do have jurisdiction to enforce a collective-bargaining agreement and to enjoin a strike in violation of a 'no-strike' clause contained therein, but not when the strike is also arguably an unfair labor practice prohibited by federal law.”
The Florida Supreme Court's initial holding that was reversed by the U.S. Supreme Court
Previewing 1 of 2 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceWilliam E. Arnold Co. sought to enjoin a strike by the Carpenters Union, alleging breach of a no-strike clause in their collective-bargaining agreemen…
The full statement of facts, procedural history, and disposition for this case are member content.
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McCAIN, Justice.
This case is before us pursuant to a mandate of the Supreme Court of the United States,1 decided May 20, 1974, reversing a decision of this Court2 and remanding the cause for reconsideration consistent with the views expressed therein.
The suit originally sought to enjoin petitioner union’s alleged breach of a no-strike clause contained in a collective-bargaining agreement, which breach arguably is also an unfair labor practice under the Labor Management Relations Act.3 William E. Arnold Co., the plaintiff in the original action, obtained a temporary restraining order prohibiting a strike by the Carpenters Union. The Carpenters then sought a writ of prohibition from the District Court of Appeal, contending that the Circuit Court lacked jurisdiction to order injunctive relief because the alleged breach of the no-strike clause was also arguably an unfair labor practice. The District Court of Appeal denied the petition for writ of prohibition and, upon a petition for writ of certiorari, this Court reversed, holding that:
“It is unquestionable that state courts do have jurisdiction to enforce a collective-bargaining agreement and to enjoin a strike in violation of a ‘no-strike’ clause contained therein, but not when the strike is also arguably an unfair la1 bor practice prohibited by federal law.” at 302. The Supreme Court of the United States reversed this Court’s holding, stating that:
“ . . . When, however, the activity in question also constitutes a breach of a collective-bargaining agreement, the Board’s authority ‘is not exclusive and does not destroy the jurisdiction of the courts in suits under § 301.’ Smith v. Evening News Ass’n, supra, 371 U.S. , at 197, 83 S.Ct. , at 269 [9 L.Ed.2d 246]. This exception was explicitly reaffirmed in Motor Coach Employees v. Lockridge, 403 U.S. 274, 297-298, 91 S.Ct. 1909, 1923-1924, 29 L.Ed.2d 473 (1971).”
As a result of that opinion, the issue of whether the Circuit Court had jurisdiction to enter the temporary restraining order prohibiting a strike by the Carpenters Union has been resolved.
For this reason the cause is remanded to the District Court of Appeal for further proceedings consistent herewith.
It is so ordered.
ADKINS, C. J., and ERVIN, BOYD and DEKLE, JJ., concur. . Styled: William E. Arnold Co. v. Carpenters District Council of Jacksonville and vicinity et al., 417 U.S. 12, 94 S.Ct. 2069, 40 L.Ed.2d 620.
. 279 So. 2d 300 (1973).
. 29 U.S.C. § 185.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Smith v. Evening News Ass'n, 371 U.S. 195 (U.S. 1962)
- Amalgamated Ass'n of St. v. Lockridge, 403 U.S. 274 (U.S. 1971)
- William E. Arnold Co. v. Carpenters Dist. Council of Jacksonville & Vicinity, 417 U.S. 12 (U.S. 1974)
- LEE v. Johnston, 279 So. 2d 300 (Fla. 1973)
- Carpenters Dist. Council OF Jacksonville & Vicinity v. The Honorable Roger J. Waybright, 279 So. 2d 300 (Fla. 1973)