In the 1945 case American Federation of Labor et al. v. Watson, Attorney General, et al., the United States Supreme Court dealt with a challenge to Florida's "Right-to-Work" law by labor unions who claimed it violated their rights under the National Labor Relations Act and was thus unconstitutional. The law prohibited agreements between trade unions and employers that required employees' membership in a union as a condition of employment. The court ruled against the labor unions stating that they had no standing to sue because they failed to demonstrate any direct or immediate injury resulting from enforcement of this state statute; therefore, there was no actual controversy for adjudication. This decision upheld states' rights to pass such laws limiting union power.

In the dissenting opinion for the case of American Federation of Labor et al. v. Watson, Attorney General, et al., Justice Wiley Rutledge argued that Florida's "Right to Work" law was unconstitutional because it violated both freedom of speech and assembly as well as due process under the Fourteenth Amendment. He believed that labor unions had a constitutional right to negotiate closed-shop agreements with employers and these agreements were essential tools for collective bargaining. The majority’s decision upheld state laws prohibiting such arrangements which he saw as an infringement on union rights protected by federal law and constitutionally guaranteed freedoms. Furthermore, he contended that this ruling could potentially undermine national labor policy aimed at promoting industrial peace through collective bargaining.