In the 1980 case United Association of Journeymen & Apprentices of Plumbing & Pipefitting Industry v. United Association of Journeymen & Apprentices, the U.S Supreme Court dealt with a dispute between two factions within a union over control and representation rights. The local union had been placed in trusteeship by its international parent organization due to allegations of corruption and mismanagement. A group from within the local challenged this decision, arguing that it violated their rights under Labor-Management Reporting and Disclosure Act (LMRDA). However, the court ruled against them stating that LMRDA does not provide an absolute right to democratic processes within labor organizations but rather seeks to ensure basic standards of democracy. Therefore, imposition of trusteeship was permissible if done in accordance with constitution and bylaws of labor organization as long as it is not maintained for longer than necessary.

In the dissenting opinion for this case, it was argued that the majority's decision to uphold a union rule prohibiting members from working in nonunion shops even during strikes or lockouts is fundamentally flawed. The dissenting justices believed that such a rule infringes on workers' rights and undermines their ability to make personal decisions about employment. They contended that while unions have an important role in protecting worker interests, they should not be allowed to exert total control over individual choices regarding work opportunities. This view holds that the National Labor Relations Act (NLRA) was designed not only to protect collective bargaining but also individual employee rights, which are compromised by such restrictive union rules. Therefore, these justices disagreed with the majority's interpretation of federal labor law and its application in this case.