Rhode Island

Boys Markets, Inc. v. Retail Clerks Union, Local 770 in Rhode Island Law

How Boys Markets, Inc. v. Retail Clerks Union, Local 770 applies in Rhode Island: state-specific rules, key cases, and bar exam notes for Labor Law.

State Approach

Rhode Island follows a similar approach to federal labor law regarding secondary boycotts and injunctions as established in Boys Markets. The state recognizes that while unions have the right to strike, there are limitations when it interferes with secondary parties not involved in the primary dispute.

State Rule
In Rhode Island, a court may grant an injunction against a union's strike if it is deemed to be an unlawful secondary boycott or if it impermissibly disrupts business relations and violates collective bargaining agreements.
Significant State Cases

Rhode Island Laborers' District Council v. City of Providence

The court held that an injunction could be issued against a union's work stoppage that affected a third party, aligning with Boys Markets principles.

Newport Shipyard, Inc. v. Local 6, International Association of Machinists

The court ruled that secondary boycotts that cause significant economic harm to non-striking entities are subject to injunction.

United Brotherhood of Carpenters and Joiners v. Bassett

The ruling emphasized that labor actions taking place beyond the realm of primary disputes may be restrained by the court to prevent business disruptions.

Comparison to Federal Law

Rhode Island's approach parallels the federal labor law framework established by the National Labor Relations Act (NLRA), particularly concerning schemes to prevent secondary boycotts. However, Rhode Island courts may adopt a slightly more stringent stance on protecting non-union businesses from union disruptions than some federal jurisdictions.

Bar Exam Note

Questions related to Boys Markets and its implications on labor disputes may appear on the Rhode Island bar exam, particularly in the context of injunctions and secondary boycotts.

Practice Pointers
  • Familiarize yourself with the key principles of Boys Markets and how they are articulated in Rhode Island case law.
  • Understand the differences between primary and secondary disputes and how injunctions apply in both contexts.
  • Keep up-to-date with any legislative changes in Rhode Island that may impact labor law and union activities.

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