In the 1953 case Garner et al., Trading as Central Storage & Transfer Co. v. Teamsters, Chauffeurs and Helpers Local Union No. 776 (A.F.L.) et al., the U.S Supreme Court ruled that federal courts must abstain from intervening in labor disputes unless there is a clear violation of law or threat to public order. The case arose when a Pennsylvania storage company sought an injunction against a union for picketing during contract negotiations, arguing it was coercive and violated state law. However, the court held that under the Norris-LaGuardia Act - which limits federal courts' power to issue injunctions in labor disputes - they could not intervene unless unlawful acts were being committed or threatened beyond just peaceful picketing.

In the dissenting opinion for Garner et al., Trading as Central Storage & Transfer Co. v. Teamsters, Chauffeurs and Helpers Local Union No. 776 (A.F.L.) et al., Justice Frankfurter argued that the majority's decision was a departure from established principles of federalism and labor law policy. He contended that Congress intended to leave regulation of peaceful picketing to state courts unless it involved an issue covered by federal legislation or affected interstate commerce in a significant way - neither of which were present in this case according to him. Furthermore, he believed that the Norris-LaGuardia Act prohibited federal courts from issuing injunctions in labor disputes except under specific circumstances not applicable here; thus, he felt Pennsylvania's court had jurisdiction over this dispute rather than a Federal District Court.