NATIONAL LABOR RELATIONS BOARD v. ALLIS-CHALMERS MANUFACTURING CO. ET AL., 388 U.S. 175

Summary

The union imposed fines against employees, who crossed picket lines and worked for the employer during a lawful economic strike. The National Labor Relations Board rejected respondent's allegation that the union's fines violated the National Labor Relations Act, 29 U.S.C.S. § 158(b)(1)(A). The appellate court reversed the Board's decision. The Supreme Court reversed that judgment. A literal interpretation of the phrase "restrain and coerce," to find that § 158(b)(1)(A) stripped unions of their power to fine members for strikebreaking, was at odds with Congress' understanding of the union-membership relations and the national labor policy. Additionally, the legislative history and the 1959 Landrum-Griffin amendments indicated that Congress' intent in enacting § 158(b)(1)(A) was not to regulate internal union affairs.