In the case of Local Union No. 10, United Association of Journeymen Plumbers & Steamfitters, et al. v. Graham et al., trading as Graham Brothers (1952), the Supreme Court ruled on a dispute between a local union and an employer over collective bargaining agreements and labor practices. The union had sued for damages after alleging that the employer violated their agreement by subcontracting work to non-union workers without paying them at agreed-upon rates or providing benefits stipulated in the contract with the union members. The court held that federal courts do not have jurisdiction under Section 301(a) of Labor Management Relations Act to award damages against employers who breach collective bargaining contracts with unions unless it can be shown there is diversity of citizenship or other grounds for federal jurisdiction independent from Section 301(a). This decision clarified that while breaches may occur, they are matters for state courts unless specific conditions apply.

In the dissenting opinion for Local Union No. 10, United Association of Journeymen Plumbers & Steamfitters, et al. v. Graham et al., trading as Graham Brothers (1952), Justice Frankfurter argued that the majority's decision to uphold a state court injunction against union picketing was an overreach and misinterpretation of federal labor law. He contended that Congress had intended to leave such matters primarily in the hands of National Labor Relations Board (NLRB). The justice believed this case should have been deferred to NLRB because it involved complex issues related to labor disputes which are better suited for administrative expertise rather than judicial intervention. Furthermore, he warned that allowing state courts to intervene could lead to inconsistent interpretations and applications of national labor policy across different states thereby undermining uniformity in federal laws governing industrial relations.