In the 1970 case Hodgson, Secretary of Labor v. Local Union 6799, United Steelworkers of America, AFL-CIO et al., the US Supreme Court ruled on a dispute involving union elections and federal labor law. The Secretary of Labor had filed suit against a local steelworkers' union after allegations that their election was not conducted in accordance with federal laws outlined in Title IV of the Labor-Management Reporting and Disclosure Act (LMRDA). The District Court initially dismissed the complaint due to lack of jurisdiction because it believed that internal remedies within the union hadn't been exhausted yet. However, upon reaching Supreme Court level, it was held that exhaustion wasn’t necessary under LMRDA before filing such suits by Department Of Labour(DOL) as DOL's role is to protect public rights rather than settling private disputes among members or between members & unions. Therefore,the decision reversed lower court’s ruling thereby allowing DOL to proceed with its lawsuit without requiring exhaustion.

In the dissenting opinion for Hodgson v. Local Union 6799, United Steelworkers of America, AFL-CIO, Justice Hugo Black argued that the Secretary of Labor did not have authority to sue a union on behalf of its members under Title IV of the Labor-Management Reporting and Disclosure Act (LMRDA). He contended that Congress intended for individual union members to bring such suits themselves. Furthermore, he believed that allowing the Secretary to sue could potentially infrive upon unions' rights to self-governance and autonomy. Justice Black also expressed concern about potential misuse or abuse by government officials who might use this power as leverage over unions in political disputes or labor negotiations. He concluded his dissent by stating that if there were abuses within a union's election process, it should be up to individual members - those directly affected - rather than governmental authorities like the Secretary of Labor - an outsider with no personal stake in these internal affairs –to take legal action.