In the 1964 case of Radio & Television Broadcast Technicians Local Union 1264, International Brotherhood of Electrical Workers, AFL-CIO et al. v. Broadcast Service of Mobile Inc., the U.S Supreme Court dealt with a dispute between a local union and a broadcasting company over collective bargaining agreements. The union had sought to enforce an arbitration award that required reinstatement and back pay for two employees who were discharged by the company allegedly without just cause as per their agreement. However, the broadcasting service argued that it was not bound by this decision because it did not participate in selecting arbitrators or agree to submit any disputes to them as mandated under federal law (Section 301(a) Labor Management Relations Act). The court ruled in favor of the broadcast service stating that while unions can negotiate contracts requiring binding arbitration for grievances, they cannot unilaterally impose such procedures on employers who have not agreed to them.

In the dissenting opinion for the case of Radio & Television Broadcast Technicians Local Union 1264, International Brotherhood of Electrical Workers, AFL-CIO, et al. v. Broadcast Service of Mobile, Inc., Justice Goldberg argued that the National Labor Relations Board (NLRB) was incorrect in its decision to not enforce a union security clause in an agreement between a labor union and an employer. The NLRB had ruled that such enforcement would violate Section 8(a)(3) of the National Labor Relations Act because it could lead to employees being fired for failing to pay dues or initiation fees. However, Justice Goldberg contended that this interpretation was overly broad and inconsistent with previous rulings by both Congress and courts which upheld similar clauses as long as they did not result in actual discrimination against non-union workers.