In the case of Order of Railroad Telegraphers et al. v. Chicago & North Western Railway Co., 1959, the U.S Supreme Court ruled in favor of labor unions' right to strike under certain circumstances. The dispute arose when a railway company decided to close several small stations, which would result in job losses for union members. The union sought an injunction against these closures and announced their intention to strike if they went ahead. Initially, lower courts sided with the railway company on grounds that strikes over minor disputes were prohibited by the Railway Labor Act (RLA). However, upon reaching the Supreme Court, it was determined that while RLA did aim at preventing interruptions in commerce due to labor disputes through mediation and arbitration processes; it did not explicitly prohibit strikes over 'minor' issues such as this one where negotiation had failed or been refused by management side.

In the dissenting opinion for the case of Order of Railroad Telegraphers et al. v. Chicago & North Western Railway Co., Justice Brennan, joined by Chief Justice Warren and Justices Black and Douglas, argued that an injunction should not have been granted against a strike by railroad telegraph operators because it was based on labor disputes over compulsory overtime - a minor dispute under the Railway Labor Act (RLA). They contended that such minor disputes are to be resolved through collective bargaining or arbitration rather than court intervention. The majority's decision to allow courts to intervene in this way would undermine the RLA’s purpose of promoting stability in labor relations within the railway industry by encouraging negotiation and voluntary agreement between parties without resorting to strikes or lockouts. Furthermore, they expressed concern about potential abuse where employers could provoke minor disputes as a strategy to secure injunctive relief against strikes.