In the 1962 case of Brotherhood of Locomotive Engineers et al. v. Baltimore & Ohio Railroad Co. et al., the U.S Supreme Court ruled on a dispute between railroad companies and their employees' unions over pay rates for "deadhead" trips, where workers travel without performing any work duties. The railroads had unilaterally reduced these rates, prompting union objections that this violated collective bargaining agreements under the Railway Labor Act (RLA). The court held that such disputes were minor and should be resolved by arbitration through the National Railroad Adjustment Board as per RLA provisions rather than in courts or strikes. This decision underscored how federal labor law prioritizes maintaining uninterrupted service in vital industries like rail transport over individual employment contract issues.

In the dissenting opinion for Brotherhood of Locomotive Engineers et al. v. Baltimore & Ohio Railroad Co. et al., Justice Douglas argued that the majority's decision to allow a railroad company to unilaterally change work rules without negotiation with unions was contrary to the Railway Labor Act’s purpose and intent, which is designed to promote collective bargaining and prevent labor disputes from disrupting interstate commerce. He contended that allowing companies such unilateral power would undermine these goals by encouraging them not only to bypass negotiations but also potentially provoke strikes or other disruptive actions in response from workers who feel their rights have been violated. Furthermore, he expressed concern about setting a precedent where courts could interpret statutes based on economic considerations rather than legislative intent.