In the case of Cuyahoga Valley Railway Co. v. United Transportation Union et al., 1985, the U.S Supreme Court was asked to decide whether a federal court could enjoin a strike by railway workers under the Railway Labor Act (RLA). The dispute arose when Cuyahoga Valley Scenic Railroad, a non-profit organization operating on tracks owned by National Park Service, refused to recognize or negotiate with United Transportation Union as representative of its employees. The union called for a strike and the railroad company sought an injunction from federal courts arguing that they were not subject to RLA because they are not "a carrier providing transportation subject to jurisdiction under interstate commerce laws". Both District Court and Sixth Circuit sided with UTU stating that CVSR is indeed covered by RLA hence cannot be enjoined from striking. However, Supreme Court reversed these decisions holding that since CVSR does not engage in commercial activity nor operates for profit but rather provides recreational excursions within national park boundaries only; it doesn't fall under definition of 'carrier' in context of RLA thus can seek injunction against strikes.

In the dissenting opinion for Cuyahoga Valley Railway Co. v. United Transportation Union et al., Justice Brennan, joined by Justices Marshall and Blackmun, disagreed with the majority's interpretation of the Norris-LaGuardia Act in relation to labor disputes involving railroads. The dissent argued that Congress intended a broad application of this act which would limit federal courts' power to issue injunctions in all labor disputes, not just those involving strikes or other concerted activities as interpreted by the majority. They contended that this broader interpretation was supported by both legislative history and previous court decisions interpreting similar language in related statutes such as Railway Labor Act (RLA). Furthermore, they believed that even if an exception existed for minor disputes under RLA - it should be narrowly construed so as not to undermine Norris-LaGuardia’s general policy against judicial intervention in labor disputes.