In the case of Chicago & North Western Railway Co. v. United Transportation Union, 1970, the U.S Supreme Court ruled in favor of the railway company by a vote of 6-3. The dispute arose when the union demanded that firemen be employed on diesel locomotives and threatened to strike if this was not implemented. The railway company argued that such employment was unnecessary and costly as technology had advanced beyond needing firemen on these types of trains. They sought an injunction against any potential strikes from federal courts which was initially denied but later granted by an appellate court under Norris-LaGuardia Act - a law limiting courts' power to issue injunctions in labor disputes. The Supreme Court held that while Norris-LaGuardia Act generally prohibits federal courts from issuing injunctions in cases involving or growing out of labor disputes, it does not apply where national interests are at stake such as maintaining uninterrupted interstate commerce operations during railroad labor disputes over minor grievances (which is regulated by Railway Labor Act). Therefore, they upheld issuance of anti-strike order preventing disruption to rail services.

In the dissenting opinion for Chicago & Northwestern Railway Co. v. United Transportation Union, Justice Black disagreed with the majority's decision to uphold a federal district court's injunction against a railway workers' strike. He argued that Congress intended to limit courts' power to issue such injunctions under the Norris-LaGuardia Act and that this intent should be respected unless there is clear evidence of congressional approval for an exception in later legislation, which he did not believe existed in this case. Furthermore, he contended that allowing courts broad authority to intervene in labor disputes could undermine collective bargaining by encouraging employers or unions to seek judicial intervention rather than negotiate settlements themselves.