The U.S. Supreme Court case Hanna Mining Co. et al. v. District 2, Marine Engineers Beneficial Association, AFL-CIO, et al., in 1965 revolved around a labor dispute between the Hanna Mining Company and its employees who were members of the Marine Engineers Beneficial Association (MEBA). The company had sought an injunction against MEBA's picketing activities on grounds that they violated federal law prohibiting secondary boycotts under the Labor Management Relations Act of 1947 (LMRA), also known as Taft-Hartley Act. The lower courts ruled in favor of MEBA stating that it was not engaged in illegal activity because their actions constituted primary rather than secondary action since they directly targeted their employer instead of involving neutral third parties to pressure their employer indirectly which is considered a secondary boycott under LMRA . However, upon reaching the Supreme Court, this decision was overturned with justices ruling unanimously for Hanna Mining Co., asserting that such picketing did indeed constitute an unlawful secondary boycott under federal law.

In the dissenting opinion for Hanna Mining Co. v. District 2, Marine Engineers Beneficial Association, AFL-CIO, Justice Harlan disagreed with the majority's interpretation of Section 301(a) of the Labor Management Relations Act (LMRA). He argued that this section should not be used to create a federal common law applicable to all collective bargaining agreements but rather it should only provide jurisdiction for federal courts over such disputes. The justice believed that state laws were more than capable of handling these issues and there was no need for a uniform national labor policy in this regard. Furthermore, he contended that creating such a federal common law would unnecessarily interfere with states' rights and potentially lead to conflicts between state and federal laws on labor relations matters.