398 U.S. 235 (1970) (U.S. Supreme Court)
Boys Markets, Inc. v.
Whether a federal court, consistent with the Norris–LaGuardia Act, may enjoin a strike that violates a no-strike clause when the underlying dispute is subject to mandatory arbitration under a collective-bargaining agreement, pursuant to §301 of the LMRA.
Federal courts may issue a narrowly tailored injunction to restrain strike activity that breaches a no-strike clause where (1) the collective-bargaining agreement contains a mandatory grievance-arbitration provision, (2) the strike is over a dispute that the parties are contractually bound to arbitrate (i.e., the dispute is at least arguably arbitrable), (3) the employer is willing to arbitrate and is not in default of its contractual obligations, and (4) traditional equitable principles, including the specific findings required by §7 of the Norris–LaGuardia Act (e.g., irreparable injury, inadequate remedy at law, balance of hardships, and inability of public authorities to protect the property), are satisfied. To the extent inconsistent, Sinclair Refining Co. v. Atkinson is overruled.
Yes. A federal court may enjoin a strike in violation of a no-strike clause when the underlying dispute is subject to binding arbitration under the CBA, provided the court makes the requisite equitable and statutory findings and conditions relief on the parties' submission of the dispute to arbitration.
Boys Markets is the foundation for the so-called "Boys Markets injunction," a narrow but critical exception to the Norris–LaGuardia Act that enables courts to preserve the parties' arbitral bargain by halting strikes over arbitrable grievances. It operationalizes the no-strike/arbitration exchange central to collective bargaining and ensures that arbitration remains the primary method of dispute resolution in unionized workplaces. For law students, the case illustrates statutory reconciliation, the interplay between federal labor policy and equitable remedies, and the judicial role in policing the boundaries of labor arbitration. Its limits are equally important: later cases, notably Buffalo Forge Co. v. United Steelworkers (1976), constrain Boys Markets by forbidding injunctions where the strike concerns a dispute not subject to arbitration (e.g., a sympathy strike) and by preventing courts from reaching the merits of the underlying grievance at the injunction stage. Other decisions, such as Gateway Coal Co. v. UMW (1974), apply Boys Markets to different contexts, reinforcing that the doctrine exists to protect the arbitral forum, not to expand general labor injunctions.