In the case of International Union, United Automobile, Aerospace & Agricultural Implement Workers of America, AFL-CIO, Local 283 v. Scofield et al., the Supreme Court ruled in favor of a union's right to enforce rules that limit production by its members. The dispute arose when two employees at a Michigan factory were expelled from their local union for violating an internal rule limiting individual output. They sued on grounds that this violated federal labor law which prohibits unions from causing employers to discriminate against workers who refuse to participate in collective activities. However, the Supreme Court held that such laws do not prevent unions from enforcing self-imposed restrictions on work rates as long as they are not used discriminatorily or in bad faith and do not conflict with national labor policy objectives.

In the dissenting opinion for the case of International Union, United Automobile, Aerospace & Agricultural Implement Workers of America, AFL-CIO, Local 283 v. Scofield et al., Justice Harlan argued that the National Labor Relations Board (NLRB) had overstepped its authority by interfering in a dispute between an employer and union concerning internal union rules. He contended that Congress did not intend for the NLRB to have such broad powers when it passed labor laws like The Wagner Act or Taft-Hartley Act. Instead, he believed these laws were designed to protect workers' rights to organize and bargain collectively without interference from employers - not regulate unions themselves. Furthermore, he asserted that this decision could potentially lead to excessive government intrusion into private organizations' affairs which would be detrimental towards maintaining a free society.