In the case of Gateway Coal Co. v. United Mine Workers of America et al., 1973, the U.S. Supreme Court ruled that a union could be held liable for damages caused by wildcat strikes (unauthorized or unofficial labor strikes) if it was proven that they had instigated, supported, or ratified these actions in any way. The court also determined that an arbitrator's decision to reinstate workers fired due to their participation in such unauthorized strikes did not infringe on management rights under collective bargaining agreements and was within the scope of his authority as defined by federal law governing labor disputes resolution procedures. This ruling clarified how liability for illegal strike activities should be assigned and affirmed the role of arbitration in resolving conflicts between employers and unions.

In the dissenting opinion for Gateway Coal Co. v. United Mine Workers of America, Justice Douglas argued that the majority's decision was a departure from established labor law principles and an intrusion into collective bargaining agreements between employers and unions. He contended that by allowing courts to issue injunctions against strikes over arbitrable disputes, the Supreme Court was undermining workers' rights to strike as a means of exerting economic pressure on their employers during negotiations or disagreements about contract terms. Furthermore, he expressed concern that this ruling could lead to judicial interference in other aspects of labor relations traditionally left up to negotiation between parties involved in collective bargaining agreements.