The U.S. Supreme Court case National Labor Relations Board v. Granite State Joint Board, Textile Workers Union of America, Local 1029, AFL-CIO (1972) revolved around the issue of whether a union could be held in contempt for violating an injunction that prohibited it from picketing at a business where it was not the recognized bargaining representative. The union had been picketing at two businesses to pressure them into recognizing and negotiating with the union as their employees' exclusive bargaining agent. The National Labor Relations Board (NLRB) sought an injunction against this activity which was granted by lower courts but violated by the union leading to contempt proceedings. In its decision, the Supreme Court ruled that unions can indeed be held in contempt for such violations and upheld penalties imposed on the defendant labor organization.

In the dissenting opinion for the National Labor Relations Board v. Granite State Joint Board, Textile Workers Union of America, Local 1029, AFL-CIO case in 1972, it was argued that the majority's decision to uphold an NLRB order against a union for refusing to bargain with an employer over changes in working conditions during contract negotiations was incorrect. The dissenting justices believed that this ruling undermined collective bargaining by forcing unions into premature discussions about terms and conditions before they had a chance to fully negotiate their contracts. They also disagreed with the majority's interpretation of Section 8(d) of the National Labor Relations Act (NLRA), arguing that it did not require parties to discuss all issues at once or prevent them from delaying talks until after other matters were settled. Furthermore, they contended that such forced bargaining could lead to unnecessary labor disputes and strikes as unions might feel pressured into making concessions just to avoid being accused of unfair labor practices.