In the case of New Negro Alliance v. Sanitary Grocery Co., 1937, the United States Supreme Court ruled in favor of the New Negro Alliance (NNA), a group that was protesting against discriminatory hiring practices by Sanitary Grocery Company. The grocery company had sought an injunction to stop NNA's picketing and boycotts on grounds that they violated a federal anti-trust law known as Norris-LaGuardia Act which protected businesses from certain union activities. However, the court held that peaceful protests advocating for fair employment were not violations under this act. The ruling upheld citizens' right to protest peacefully against racial discrimination and marked an important victory for civil rights activists during this era.

In the dissenting opinion for New Negro Alliance v. Sanitary Grocery Co., Justice McReynolds disagreed with the majority's interpretation of Section 20 of the Clayton Act, which prohibits injunctions in labor disputes. He argued that this case was not a labor dispute as defined by law because it involved an organization seeking to force an employer to hire only individuals from a specific racial group, rather than employees fighting for improved working conditions or wages. Furthermore, he contended that picketing and boycotting were coercive actions intended to harm business operations and should be considered illegal under common law principles. Therefore, he believed that these activities did not fall within the protections granted by Section 20 of the Clayton Act and could be restrained through legal means such as injunctions.