The U.S. Supreme Court case International Union, United Automobile, Aerospace & Agricultural Implement Workers of America (UAW), AFL-CIO v. Hoosier Cardinal Corp., 1965 revolved around a dispute over whether or not the six-year statute of limitations for contract actions in Indiana applied to suits under §301(a) of the Labor Management Relations Act. The union had sued an employer for violating a collective bargaining agreement by failing to make required payments into various employee benefit funds and sought damages on behalf of its members who were employees at the company. The District Court dismissed the complaint as untimely under Indiana's six-year limitation period for actions upon contracts not in writing while reversing this decision, the Court of Appeals held that federal law governed and remanded it back to determine what reasonable time limit should apply. However, when taken up by Supreme court it ruled that state statutes do indeed apply where there is no specifically stated or relevant federal statute regarding timelines; thus affirming that Indiana’s six year contractual limitation was applicable here.

In the dissenting opinion for the case of International Union, UAW v. Hoosier Cardinal Corp., Justice Black argued that federal courts should not be allowed to create a new federal common law in labor cases. He believed that Congress had intended for state laws to govern such disputes when it passed the Labor Management Relations Act (LMRA). According to him, allowing federal courts to develop their own body of law would undermine this intention and lead to inconsistencies across different jurisdictions. Furthermore, he pointed out that there was no clear evidence suggesting Congress wanted these issues handled at a national level rather than by individual states. Therefore, he disagreed with the majority's decision which held that claims under Section 301(a) of LMRA were governed by federal common law instead of state contract law.