In the 1944 case of International Union of Mine, Mill & Smelter Workers, Locals Nos. 15, 17, 107,108 and 111 (C.I.O) v. Eagle-Picher Mining & Smelting Co., et al., the United States Supreme Court ruled on a labor dispute involving overtime pay for miners under the Fair Labor Standards Act (FLSA). The mining company argued that time spent by miners traveling to their workstations underground should not be considered as part of their regular working hours and therefore was not subject to overtime pay. However, the union contended that this travel time constituted "work" under FLSA and should be compensated accordingly. The Supreme Court sided with the mining company in a decision that significantly narrowed what could be considered compensable work time under federal law.

In the dissenting opinion for the case of International Union of Mine, Mill & Smelter Workers, Locals Nos. 15, 17, 107, 108 and 111 (C.I.O.) v. Eagle-Picher Mining & Smelting Co., Justice Frank Murphy argued that the majority's decision was a departure from established principles governing labor disputes under Norris-LaGuardia Act. He contended that this act was designed to limit federal courts' interference in labor disputes unless there is clear evidence of violence or threats thereof which were not present in this case. Furthermore, he criticized the court’s interpretation of 'labor dispute', stating it should be broadly interpreted to include any controversy concerning terms or conditions of employment regardless if an employer-employee relationship exists between parties involved in dispute as per Section 13(c) Norris-LaGuardia Act definition. Lastly, he expressed concern over potential negative implications on future collective bargaining rights due to this ruling.