In the 1941 case of Allen-Bradley Local No. 1111, United Electrical, Radio & Machine Workers of America v. Wisconsin Employment Relations Board, the U.S Supreme Court ruled in favor of the Wisconsin Employment Relations Board (WERB). The dispute arose when WERB ordered a union to cease and desist from engaging in unfair labor practices such as coercing employees into joining their organization or participating in strikes against their will. The union argued that this order was an infringement on its rights under federal law which allowed for collective bargaining and striking activities. However, the court held that while federal law did grant these rights to unions, it did not preclude states from regulating these activities within reasonable bounds to prevent coercion or intimidation tactics by unions towards workers who chose not to participate.

In the dissenting opinion for Allen-Bradley Local No. 1111, United Electrical, Radio & Machine Workers of America v. Wisconsin Employment Relations Board et al., Justice Frank Murphy argued that the majority's decision was a departure from established principles of federal labor law and policy. He contended that Congress had intended to create an exclusive national system for resolving disputes between employers and employees in industries affecting interstate commerce through the National Labor Relations Act (NLRA). By allowing states to regulate these same disputes, he believed it would lead to confusion and conflict due to differing state laws and policies. Furthermore, he expressed concern about potential infringement on workers' rights by state interference with collective bargaining processes protected under NLRA. Thus, according to him, such matters should be left solely within federal jurisdiction as per congressional intent.