In the case of International Union of Electrical, Radio & Machine Workers, AFL-CIO, Local 790 v. Robbins & Myers Inc., et al., the U.S Supreme Court was tasked with determining whether an employer could be held in contempt for violating a court order that prohibited it from discriminating against employees who were engaged in union activities. The dispute arose when Robbins & Myers fired several employees due to their involvement in union activities. A district court issued an injunction prohibiting such discrimination and later found Robbins & Myers guilty of contempt for violating this injunction by firing another employee involved in union activity. The Supreme Court reversed this decision on appeal, ruling that before finding an employer guilty of contempt for violation of such a prohibition order, there must be clear and convincing proof beyond reasonable doubt that the alleged discriminatory conduct occurred specifically because of the employee's engagement in protected labor activities. It is not enough to show mere coincidence between anti-union sentiment and adverse action against an employee; there must be evidence showing causation.

In the dissenting opinion for the case of International Union of Electrical, Radio & Machine Workers, AFL-CIO, Local 790 v. Robbins & Myers, Inc., Justice Brennan argued that the majority's interpretation was too narrow and did not fully consider Congress' intent when it enacted Section 301(a) of Labor Management Relations Act (LMRA). He believed that this section should be interpreted to allow unions to sue on behalf of their members without needing individual authorization from each member. This broader interpretation would better serve Congress' goal in enacting LMRA: promoting collective bargaining and peaceful labor relations. Furthermore, he pointed out that requiring individual authorizations could lead to practical difficulties as well as undermine union solidarity by encouraging individual rather than collective action. Thus, he disagreed with the majority's decision which required a union obtain specific authorization from each employee before filing suit under Section 301(a) on their behalf.