Textile Workers Union of America v. Lincoln Mills of Alabama, 353 U.S. 448 (1957) (U.S. Supreme Court)
Textile Workers Union v. Lincoln Mills is a foundational labor law and federal courts decision that situates arbitration at the heart of the federal labor policy and confirms a robust role for the federal judiciary in enforcing collective bargaining agreements (CBAs).
Does § 301(a) of the Labor Management Relations Act authorize federal courts to decree specific performance of a collective bargaining agreement's promise to arbitrate and to fashion a body of federal common law governing suits for violation of such agreements?
Yes. Section 301(a) of the LMRA provides both jurisdiction and authority for federal courts to apply federal substantive law to suits for violation of collective bargaining agreements. In enforcing § 301, federal courts are to fashion a body of federal common law from national labor policy, and that federal law includes the power to decree specific performance of promises to arbitrate grievances under CBAs. State law may be consulted where compatible, but it does not control and must yield to federal labor policy.
The Supreme Court reversed the court of appeals and held that § 301 authorizes federal courts to order specific performance of an agreement to arbitrate labor grievances and to develop and apply federal common law in suits alleging violations of collective bargaining agreements.
Lincoln Mills is the gateway to the federal common law of labor contracts. It establishes that § 301 is not merely jurisdictional; it authorizes federal courts to develop substantive rules that give force to CBAs, especially arbitration provisions. The decision laid the doctrinal groundwork for the Steelworkers Trilogy, which entrenched a strong presumption of arbitrability and severely limited judicial review of arbitration awards. For students and practitioners, Lincoln Mills explains why federal law governs CBA disputes in federal court, how Norris–LaGuardia coexists with arbitration enforcement, and why uniformity in interpreting CBAs is crucial to the national labor policy.