In the case of Elgin, Joliet & Eastern Railway Co. v. Burley et al., 1945, the U.S Supreme Court was tasked with determining whether a railway company could unilaterally change wage rates without first negotiating with its employees' representative union under the Railway Labor Act (RLA). The dispute arose when the railway company reduced wages for certain workers without consulting their union representatives. The court ruled in favor of Burley and his fellow employees, stating that unilateral changes to working conditions were not permissible under RLA unless negotiations had reached an impasse or deadlock after good faith efforts from both parties involved. This decision reinforced collective bargaining rights and emphasized that employers must negotiate in good faith before implementing significant changes affecting their workforce.

In the dissenting opinion for Elgin, Joliet & Eastern Railway Co. v. Burley et al., Justice Frankfurter argued that the majority's decision to allow individual employees to sue their employer over wage disputes under the Railway Labor Act was a misinterpretation of Congress' intent and would undermine collective bargaining agreements. He contended that allowing such lawsuits could lead to inconsistent results and disrupt labor relations in industries covered by this law. Furthermore, he believed it was not within the Court’s jurisdiction to interpret or enforce contracts between private parties unless there is an explicit provision in federal legislation authorizing them to do so - which he claimed did not exist in this case. In his view, these matters should be left up to state courts and arbitration processes agreed upon by unions and employers.