In the case of Charles D. Bonanno Linen Service, Inc. v. National Labor Relations Board (1981), the U.S Supreme Court ruled in favor of the National Labor Relations Board (NLRB). The dispute arose when Bonanno Linen Service withdrew from a multi-employer bargaining unit during an ongoing labor negotiation without mutual consent or substantial impasse, which was deemed unlawful by NLRB under Section 8(a)(5) and Section 8(b)(3) of the National Labor Relations Act. The company argued that it had a statutory right to withdraw at any time before reaching an agreement with its employees' union but this argument was rejected by both lower courts and later by Supreme Court as well. It held that such unilateral withdrawal disrupts stability in collective bargaining process and undermines labor relations policy encouraging collective negotiations.

In the dissenting opinion for Charles D. Bonanno Linen Service, Inc. v. National Labor Relations Board et al., Justice Powell argued that the majority's decision to uphold an order from the National Labor Relations Board (NLRB) was incorrect because it failed to consider whether a multiemployer bargaining unit could be dissolved unilaterally by one of its members during a labor dispute impasse without violating federal law. He contended that such unilateral action should only be permissible if there is mutual consent among all parties involved or if there are extraordinary circumstances present which would justify dissolution of the bargaining unit. According to him, neither condition was met in this case and therefore, he believed that Bonanno Linen Service had violated federal law when it withdrew from negotiations with its unionized employees' representative during an ongoing contract dispute.