The question
Whether district courts deciding a National Labor Relations Board request for a preliminary injunction under Section 10(j) of the National Labor Relations Act must apply the traditional four-factor equitable test or a less demanding standard.
Starbucks Corp. v. McKinney
What the Court decided
The Court vacated and remanded. District courts weighing an NLRB request for a preliminary injunction under Section 10(j) of the National Labor Relations Act must apply the traditional four-factor test from Winter v. Natural Resources Defense Council, not the more lenient two-part reasonable-cause standard the Sixth Circuit used. Because Congress authorized courts to grant relief they deem just and proper, a strong presumption holds that courts exercise that power under traditional equitable principles, and nothing in Section 10(j) displaces that presumption.
How the justices split
8-1The Court's opinion
Thomas, joined by Roberts, Alito, Sotomayor, Kagan, Gorsuch, Kavanaugh, Barrett
Section 10(j) authorizes district courts to grant temporary relief they deem just and proper, and when Congress empowers courts to grant equitable relief a strong presumption holds that courts exercise that authority under traditional principles of equity. The four Winter factors capture those principles for preliminary injunctions. Nothing in Section 10(j) displaces that presumption, and its text does not resemble language Congress uses when it alters the normal equitable rules. Courts therefore must apply the traditional four-factor Winter test rather than a less exacting standard.
Concurring in part and in the judgment
Jackson, writing alone
Jackson concurred in part, concurred in the judgment, and dissented in part, agreeing with the outcome while disagreeing with part of the Court's reasoning about how the Winter factors apply to Section 10(j) petitions.
How we know · 5 sourced claims
District courts considering an NLRB request for a preliminary injunction under Section 10(j) must apply the traditional four-factor test from Winter v. Natural Resources Defense Council.
Source: syllabus, Held
When Congress empowers courts to grant equitable relief, a strong presumption holds that courts will exercise that authority consistent with traditional principles of equity, and nothing in Section 10(j) displaces that presumption.
Source: syllabus, Held
The District Court granted the injunction using a two-part reasonable-cause and just-and-proper test, and the Sixth Circuit affirmed.
Source: syllabus, Held
Thomas delivered the opinion of the Court, joined by Roberts, Alito, Sotomayor, Kagan, Gorsuch, Kavanaugh, and Barrett.
Source: syllabus, lineup
Jackson filed an opinion concurring in part, concurring in the judgment, and dissenting in part.
Source: syllabus, lineup