The U.S. Supreme Court case International Ladies' Garment Workers' Union et al. v. Donnelly Garment Co. et al., revolved around labor disputes and the right to strike in 1937. The International Ladies’ Garment Workers’ Union (ILGWU) was accused by the Donnelly Garment Company of violating an anti-trust act, claiming that their strikes were a form of illegal monopoly and restraint of trade practices under the Sherman Act due to their attempts to become the sole bargaining agent for workers in garment factories nationwide, including those at Donnelly's company who had not elected them as representatives. However, ILGWU argued that they were simply exercising their rights under Section 7(a) of National Industrial Recovery Act which allowed employees "to organize and bargain collectively through representatives of their own choosing." The Supreme Court ruled in favor of ILGWU stating that labor unions are not subject to antitrust laws unless they combine with non-labor groups such as businesses or have objectives causing substantial economic harm beyond improving wages or working conditions for members.

In the dissenting opinion for the International Ladies' Garment Workers' Union v. Donnelly Garment Co., Justice McReynolds expressed his concern that the majority's decision would allow unions to use their power in a way that could harm individual businesses and workers who chose not to join them. He argued that by allowing unions to strike against companies like Donnelly, which had chosen not to recognize or negotiate with them, the court was effectively forcing those companies into submission. This, he believed, violated principles of freedom and liberty as it took away an individual’s right to choose whether or not they wanted union representation. Furthermore, he contended this ruling could lead unions towards monopolistic practices and potentially disrupt free competition within industries.