Episode description

Welcome to Supreme Court Opinions. In this episode, you’ll hear the Court’s opinion in Starbucks Corp. v McKinney.

In this case, the court considered this issue: What test must courts use to evaluate requests for injunctions under Section 10(j) of the National Labor Relations Act?

The case was decided on June 13, 2024.

The Supreme Court held that when considering the NLRB’s request for a preliminary injunction under §10( j), district courts must apply the traditional four factors articulated in Winter v Natural Resources Defense Council, Inc.

Section 10( j) authorizes a federal district court “to grant . . . such temporary relief . empowers courts to grant equitable relief, there is a strong presumption that courts will exercise that authority in a manner consistent with traditional principles of equity. For preliminary injunctions, the four criteria identified in Winter encompass the relevant equitable principles. Nothing in §10( j) displaces the presumption that those traditional principles govern. 

The traditional rule is that a plaintiff seeking a preliminary injunction must make a clear showing that “he is likely to succeed on the merits, that he is likely to suffer irreparable harm in the absence of preliminary relief, that the balance of equities tips in his favor, and that an injunction is in the public interest.” “These commonplace considerations applicable to cases in which injunctions are sought in the federal courts reflect a ‘practice with a background of several hundred years of history.’ ” When interpreting a statute that authorizes federal courts to grant preliminary injunctions, the Court “does not lightly assume that Congress has intended to depart from established principles.” Absent a clear command from Congress, then, courts must adhere to the traditional four-factor test articulated in Winter.

Section 10( j)’s statutory directive to grant injunctive relief when the district court “deems” it “just and proper” does not jettison the normal equitable rules; it simply invokes the discretion that courts have traditionally exercised when faced with requests for equitable relief. Furthermore, §10( j)’s text bears no resemblance to the language that Congress has employed when it has altered the normal equitable rules. 

The opinion is presented here in its entirety, but with citations omitted. If you appreciate this episode, please subscribe. Thank you.