In the 1943 case, Order of Railroad Telegraphers v. Railway Express Agency, Inc., the United States Supreme Court ruled on a labor dispute involving telegraph operators and their employer. The union representing the workers had called for a strike after negotiations over working conditions broke down. In response, the company sought an injunction to prevent this action from taking place. The District Court granted this request but was later overturned by Circuit Court of Appeals who argued that Norris-LaGuardia Act removed jurisdiction in such cases from federal courts. The Supreme Court upheld this decision with Justice Frank Murphy delivering majority opinion stating that Congress intended to limit judicial interference in labor disputes when it passed Norris-LaGuardia Act which expressly prohibited federal courts from issuing injunctions in non-violent labor disputes about terms or conditions of employment. This ruling affirmed rights of unions to engage in collective bargaining and strikes without fear of court-ordered reprisals thus strengthening power and influence of organized labor during mid-twentieth century.

In the dissenting opinion for the Order of Railroad Telegraphers v. Railway Express Agency, Inc., Justice Frank Murphy argued that the majority's decision was a misinterpretation of Section 6 of the Railway Labor Act. He believed that it did not provide an absolute prohibition against strikes during negotiations or mediation but rather aimed to encourage peaceful resolution through collective bargaining and arbitration. According to him, if all negotiation efforts fail, workers should have their right to strike as a last resort measure protected by law. Furthermore, he emphasized that this interpretation aligns with both legislative intent and historical practice in labor relations within railway industry where strikes had been allowed under similar circumstances before this ruling.