Textile Workers v. Lincoln Mills, 353 U.S. 448 (1957)
For labor disputes involving federal rights, federal courts are free to construct a federal law that governs labor contracts.
Textile Workers Union had a collective bargaining agreement with Lincoln Mills, which provided that arbitration would be used to resolve disputes regarding their relationship. It sued in federal court under Section 301(a) of the Taft-Hartley Act to compel Lincoln Mills to submit to arbitration. This law allows federal courts to hear cases based on violations of labor-management agreements that affect interstate commerce. Lincoln Mills argued that Congress had acted unconstitutionality in making this grant of jurisdiction.Opinions
- William Orville Douglas (Author)
- Earl Warren
- Hugo Lafayette Black
- Tom C. Clark
- William Joseph Brennan, Jr.
- Charles Evans Whittaker
This grant of jurisdiction is constitutional because it is limited to cases that arise under federal common law, which by definition is federal law.
- Harold Hitz Burton (Author)
- John Marshall Harlan II
Cases brought under this law do not rely on federal law as the substantive law that they apply. Enforcing the law involves some federal rights, however, so it is constitutional as part of a congressional grant of protective jurisdiction to federal courts.
- Felix Frankfurter (Author)
Article III does not support the protective jurisdiction theory, which would allow Congress to give federal courts jurisdiction over applications of state laws and state court precedents. This is not a true form of federal question jurisdiction, especially since taking this theory to its conclusion would result in federal courts hearing contract and tort cases if they relate to contracts that affect commerce. Article III does not allow federal courts to create a federal common law that controls collective bargaining agreements, merely on the basis that Congress provides them with this authority under a federal law. The possibility that federal courts may eventually have appellate jurisdiction over a case does not mean that they should have original jurisdiction over it.Case Commentary
This decision illustrates how a grant of jurisdiction to the federal courts enables them to create new forms of substantive law. Even though this applies only in cases governed by federal questions, rather than diversity cases, it is historically significant.
U.S. Supreme CourtTextile Workers v. Lincoln Mills, 353 U.S. 448 (1957)
Textile Workers Union of America v. Lincoln Mills of Alabama
Argued March 25, 1957
Decided June 3, 1957
353 U.S. 448
A union entered into a collective bargaining agreement with an employer providing that there would be no strikes or work stoppages and that grievances would be handled pursuant to a specified procedure, the last step of which was arbitration. Grievances arose and were processed through various steps in the grievance procedure until the union's demands were finally denied by the employer. The union requested arbitration, and the employer refused. Thereupon, the union sued in a Federal District Court to compel arbitration.
1. Under § 301(a) of the Labor Management Relations Act of 1947, the District Court properly decreed specific performance of the agreement to arbitrate the grievance dispute. Pp. 353 U. S. 449-456.
2. The substantive law to be applied in suits under § 301(a) is federal law, which the courts must fashion from the policy of our national labor laws. Pp. 353 U. S. 456-457.
3. As here construed, § 301(a) is constitutional. P. 353 U. S. 457.
4. Jurisdiction to compel arbitration of grievance disputes is not withdrawn by the Norris-LaGuardia Act. Pp. 353 U. S. 457-459.
5. The employer in this case having ceased operations and contracted to sell its mill properties, the case is moot insofar as the union sought restoration of workloads and job assignments; but it is not moot to the extent that it sought a monetary award. P. 353 U. S. 459.
230 F.2d 81, reversed.