The U.S. Supreme Court case National Labor Relations Board v. Insurance Agents' International Union, AFL-CIO in 1959 revolved around the question of whether certain conduct during collective bargaining constituted an unfair labor practice under the National Labor Relations Act (NLRA). The Insurance Agents' International Union had engaged in various disruptive activities to pressure their employer into accepting their demands during negotiations for a new contract. The National Labor Relations Board (NLRB) held that these actions were violations of good faith bargaining requirements stipulated by NLRA and therefore constituted unfair labor practices. However, the Supreme Court disagreed with NLRB's interpretation of NLRA provisions on 'good faith' bargaining. It ruled that such disruptive tactics did not necessarily constitute bad-faith negotiation or unfair labor practices unless they significantly impeded mutual obligation between employers and employees to meet at reasonable times and confer in good faith about wages, hours, and other terms or conditions of employment. This decision clarified that while parties are required to negotiate in good faith under NLRA, this does not mean they must yield on any particular point nor refrain from using economic weapons available to them within legal limits.

In the dissenting opinion for the case of NATIONAL LABOR RELATIONS BOARD v. INSURANCE AGENTS' INTERNATIONAL UNION, AFL-CIO, Justice Frankfurter disagreed with the majority's interpretation of "unfair labor practices." He argued that Congress did not intend to include every instance where either party in a negotiation acted in bad faith as an unfair labor practice under Section 8(b)(3) of the National Labor Relations Act. Instead, he believed it was meant to cover only those actions which were coercive or disruptive to industrial peace and bargaining equality. The union’s tactics here—like demanding more than they expected to get—were simply part of hard bargaining process and should not be considered unlawful unless they involved violence or threats thereof. Furthermore, he criticized NLRB for overstepping its authority by attempting to regulate good faith negotiations between employers and unions rather than focusing on maintaining industrial peace.