The United Food and Commercial Workers Union Local 751 v. Brown Group, Inc., DBA Brown Shoe Company case in 1995 revolved around the issue of whether a labor union had standing to sue under the Worker Adjustment and Retraining Notification (WARN) Act for damages on behalf of its members who were laid off without proper notice. The WARN Act requires employers to provide employees with a 60-day notice before mass layoffs or plant closings. In this case, Brown Shoe Company closed one of its plants without giving such notice, leading to the lawsuit by UFCWU Local 751. The Supreme Court ruled that unions do have standing under Article III of the Constitution to bring suits on behalf of their members when those members have suffered an injury that is traceable back to actions taken by defendants which would be redressed if favorable court action was taken.

In the dissenting opinion for United Food and Commercial Workers Union Local 751 v. Brown Group, Inc., Justice Stevens argued that the majority's interpretation of Section 301(a) was too narrow. He believed that Congress intended to give federal courts jurisdiction over all suits involving collective bargaining agreements, not just those brought by parties to the agreement. This would include suits brought by union members against their own union or an employer. Furthermore, he disagreed with the majority's view that a suit must be based on rights created by a contract in order to fall under Section 301(a). Instead, he asserted that any suit sufficiently related to a collective bargaining agreement should qualify. Finally, Justice Stevens criticized the majority for ignoring precedent set in previous cases which supported his broader interpretation of Section 301(a).