In the case of Burlington Northern Railroad Co. et al. v. Brotherhood of Maintenance of Way Employees et al., 1986, the U.S Supreme Court was tasked with determining whether a federal court could enjoin a railroad union from striking over an issue that had been referred to arbitration by the National Railroad Adjustment Board (NRAB). The dispute arose when Burlington Northern sought to implement new work rules and conditions without negotiating them with the union, leading to a strike threat from the latter. The District Court issued an injunction against the strike, which was upheld by both Appeals Courts and eventually reached Supreme Court review. The Supreme Court ruled in favor of Burlington Northern on grounds that under Railway Labor Act provisions, minor disputes must be resolved through NRAB arbitration rather than strikes or lockouts; therefore it is within federal courts' jurisdiction to prevent such actions while awaiting resolution via this process. This decision underscored how labor law seeks balance between protecting workers’ rights for collective action and ensuring uninterrupted operation essential industries like railroads.

In the dissenting opinion for Burlington Northern Railroad Co. et al. v. Brotherhood of Maintenance of Way Employes et al., Justice Brennan, joined by Justices Marshall and Blackmun, argued that the majority's decision to allow a railroad company to unilaterally change working conditions during bargaining negotiations was contrary to the intent of Congress in passing the Railway Labor Act (RLA). They contended that such changes should only be permitted after an impasse has been reached or if both parties agree on it as part of their negotiation process. The dissenters believed that allowing unilateral changes would undermine collective bargaining and disrupt labor stability within railroads - two key objectives behind RLA's enactment. They also pointed out inconsistencies between this ruling and previous court decisions regarding similar issues under National Labor Relations Act (NLRA), which they felt were more aligned with congressional intent.