In the 1969 case of Boys Markets, Inc. v. Retail Clerks Union, Local 770, the U.S. Supreme Court ruled in favor of employers seeking injunctions against labor strikes that violated no-strike clauses in collective bargaining agreements. The court held that federal courts have jurisdiction to issue injunctions preventing such strikes when they breach existing contracts between unions and employers under specific circumstances outlined by Congress in Section 301(a) of the Labor Management Relations Act (LMRA). This decision overruled Sinclair Refining Co v Atkinson (1962), which had previously barred federal courts from issuing such injunctions due to Norris-LaGuardia Act's anti-injunction provisions. However, this ruling was limited only to cases where arbitration is available as a dispute resolution mechanism within the contract terms.

In the dissenting opinion for Boys Markets, Inc. v. Retail Clerks Union, Local 770, Justice Hugo Black argued that the majority's decision to allow federal courts to issue injunctions in labor disputes was a clear violation of the Norris-LaGuardia Act. This act had been specifically designed by Congress to limit judicial intervention in such matters and promote free collective bargaining between employers and employees. He further contended that this ruling would undermine workers' rights by allowing employers to easily obtain court orders against strikes or other union activities without having first exhausted all available arbitration procedures as required under their collective bargaining agreements. Moreover, he expressed concern about potential misuse of this new power by lower courts due to lack of specific guidelines from the Supreme Court on when it should be exercised.