The U.S. Supreme Court case Local Union No. 189, Amalgamated Meat Cutters & Butcher Workmen of North America, AFL-CIO, et al. v. Jewel Tea Co., Inc., in 1964 dealt with the issue of whether a labor union's demand for an employer to agree to arbitration over certain issues was enforceable under federal law or if it violated antitrust laws by restraining trade and competition. The court held that such demands were not inherently illegal under antitrust laws as long as they related directly to wages, hours and working conditions - areas where collective bargaining is protected by federal labor law - rather than being used as a means of controlling business decisions that should be left up to management discretion.

In the dissenting opinion for Local Union No. 189, Amalgamated Meat Cutters & Butcher Workmen of North America, AFL-CIO, et al. v. Jewel Tea Co., Inc., Justice Hugo Black argued that the majority's decision was a departure from established antitrust laws and principles which could potentially harm labor unions' bargaining power in future cases. He contended that the Court had overstepped its bounds by interpreting an exemption clause in a way not intended by Congress when it enacted the Clayton Act to protect trade union activities from being subjected to antitrust scrutiny. Furthermore, he expressed concern about how this ruling might affect other industries where similar arrangements are common practice and believed that such decisions should be left up to legislative bodies rather than courts.