The Inter-Modal Rail Employees Association and other plaintiffs filed a lawsuit against the Atchison, Topeka and Santa Fe Railway Company (ATSF) in 1996. The case revolved around ATSF's decision to use nonunion workers for its intermodal operations, which involved transferring freight between trucks and trains. The union argued that this violated their collective bargaining agreement with the railway company. However, the Supreme Court ruled in favor of ATSF stating that it was within its rights to make such decisions under federal law governing rail labor relations. Specifically, they referred to provisions of the Railway Labor Act which allows carriers like ATSF considerable latitude in managing their businesses including making operational changes without consulting unions unless specifically required by a collective bargaining agreement.

In the dissenting opinion for Inter-Modal Rail Employees Association v. Atchison, Topeka and Santa Fe Railway Company, it was argued that the majority's decision undermined collective bargaining agreements by allowing employers to unilaterally change working conditions without first negotiating with unions. The dissent asserted that this interpretation of the Railway Labor Act (RLA) contradicted its purpose - to promote stability in labor-management relations through collective bargaining. They contended that under RLA, changes in "rates of pay, rules or working conditions" must be negotiated collectively and cannot be implemented until an agreement is reached or a deadlock occurs after exhausting all negotiation procedures outlined in RLA. By permitting unilateral changes before these processes are completed, they believed it would disrupt balance between management and labor which could lead to strikes or other disruptions harmful to interstate commerce – exactly what RLA aims to prevent.