Oil Workers v. Mobil Oil Corp.
Annotate this Case
426 U.S. 407 (1976)
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U.S. Supreme Court
Oil Workers v. Mobil Oil Corp., 426 U.S. 407 (1976)
Oil, Chemical & Atomic Workers International Union,
AFL-CIO v. Mobil Oil Corp.
Argued March 29, 1976
Decided June 14, 1976
426 U.S. 407
Section 8(a)(3) of the National Labor Relations Act permits union- or agency shop agreements between employers and unions, but § 14(b) authorizes States to exempt themselves from § 8(a)(3) and to enact "right-to-work" laws prohibiting union or agency shops. About two years after petitioner unions and respondent employer had entered into an agency shop agreement covering seamen employed on respondent's oil tankers, respondent brought suit claiming that the agreement was invalid and unenforceable because it violated Texas' right-to-work laws. Since, inter alia, all final decisions for hiring the seamen are made in Texas, the majority of the then employed seamen reside in Texas, and respondent's personnel records are maintained and payroll checks are written there, the District Court held that Texas had an "intimate concern" with the agreement, notwithstanding that the seamen spend the vast majority of their working hours away from Texas on the high seas, and that therefore Texas' right-to-work laws were applicable under § 14(b) and rendered the agreement void and unenforceable. The Court of Appeals affirmed, stressing that Texas was the place of hiring.
1. lt is the employees' predominant job situs, rather than a generalized weighing of factors or the place of hiring, that triggers operation of § 14(b), and, under § 14(b), right-to-work laws cannot void agreements permitted by § 8(a)(3) when the situs at which all the employees covered by the agreement perform most of their work is located outside of a State having such laws. Pp. 426 U. S. 412-419.
(a) Insofar as § 8(a)(3) deals with union and agency shop agreements, it focuses both in effect and purpose on post-hiring conditions, conditions that have a major impact on the job situs. Pp. 426 U. S. 414-416.
(b) Similarly, § 14(b)'s primary concern is with state regulation of the post-hiring employer employee-union relationship, the center of which is the job situs, i.e., the place where the work that is the very raison d'etre of the relationship is performed; and because of this close relationship between § 14(b) and job situs, § 14(b) does not allow enforcement of right-to-work laws with regard to an employment relationship whose principal job situs is outside of a State having such laws. Pp. 426 U. S. 416-418.
(c) Under the job situs test, as opposed to a "place of hiring" test, the possibility of patently anomalous extraterritorial applications of any given State's right-to-work laws will be minimized, and parties entering a collective bargaining agreement will easily be able to determine in virtually all situations whether a union or agency shop provision is valid. Pp. 426 U. S. 418-419.
2. Under the job situs test, Texas' right-to-work laws cannot govern the validity of the agency shop agreement in question, because most of the employees' work is done on the high seas, outside the territorial bounds of Texas. It is immaterial that Texas may have more contacts than any other State with the employment relationship involved, since there is no reason to conclude under § 14(b) that, in every employment situation, some State's law with respect to union security agreements must apply, and it is fully consistent with national labor policy to conclude, if the predominant job situs is outside the boundary of any State, that no State has a sufficient interest in the employment relationship, and that, hence, no State's right-to-work laws can apply. Pp. 426 U. S. 420-421.
504 F.2d 272, reversed.
MARSHALL, J., delivered the opinion of the Court, in which BRENNAN, WHITE, BLACKMUN, and STEVENS, JJ., joined. STEVENS, J., filed a concurring statement, post, p. 426 U. S. 421. BURGER, C.J., concurred in the judgment. POWELL, J., filed an opinion concurring in the judgment, post, p. 426 U. S. 421. STEWART, J., filed a dissenting opinion, in which REHNQUIST, J., joined, post, p. 426 U. S. 422.