In the case of Fort Halifax Packing Co., Inc. v. Coyne, Director, Bureau of Labor Standards of Maine et al., 1986, the U.S Supreme Court ruled in favor of a state law requiring employers to provide one-time severance payments to employees in the event that their plant was closed down. The court held that this requirement did not infrive on federal labor laws because it didn't require ongoing administration or negotiation between parties and thus did not interfere with national labor relations policy. This decision upheld Maine's statute which mandated companies employing over 100 people at a facility for three years prior to its closure must pay each worker one week’s wages for every year worked there if they were laid off due to closure or relocation.

In the dissenting opinion for Fort Halifax Packing Co., Inc. v. Coyne, Justice Sandra Day O'Connor argued that the majority's decision was inconsistent with previous Supreme Court rulings on similar cases involving state laws and their relation to federal labor law. She contended that Maine’s statute requiring severance pay interfered with national labor policy by discouraging collective bargaining, a key component of federal labor law under the National Labor Relations Act (NLRA). The NLRA encourages free negotiation between employers and employees over terms of employment, including benefits like severance pay. By mandating certain benefits through legislation rather than leaving them open to negotiation, she believed Maine undermined this process and violated principles of federalism in U.S. government structure.