The U.S. Supreme Court case Farmer v. United Brotherhood of Carpenters & Joiners of America, Local 25 et al., dealt with the issue of whether a union could be held liable for violent acts committed by its members during a strike, even if the union did not specifically endorse or encourage such behavior. The plaintiff was seeking damages after her husband was killed in an altercation that occurred on a picket line during a labor dispute at his place of employment. The court ruled in favor of the defendant (the Union), stating that under federal law, unions cannot be held responsible for individual actions taken by their members unless it can be proven that those actions were explicitly authorized or ratified by the union itself.

In the dissenting opinion for Farmer v. United Brotherhood of Carpenters & Joiners of America, Local 25, Justice Brennan disagreed with the majority's decision to dismiss the case on grounds that it was not within federal jurisdiction. He argued that this dismissal ignored a significant issue at hand: whether or not labor unions can be held liable under antitrust laws for peaceful picketing aimed at achieving lawful collective bargaining objectives. In his view, such an important question should have been addressed by the Court rather than being dismissed due to technicalities regarding jurisdictional issues. Furthermore, he contended that previous court decisions had already established federal courts' authority over similar cases involving interstate commerce and labor disputes; thus, dismissing this case contradicted those precedents.