In the case of Brotherhood of Railway & Steamship Clerks, Freight Handlers, Express & Station Employees, AFL-CIO et al. v. Florida East Coast Railway Co., 1965, the Supreme Court ruled on a labor dispute between railway workers and their employer. The union argued that they had been unfairly denied collective bargaining rights under Section 6 of the Railway Labor Act (RLA). However, Florida East Coast Railway Company countered that it was not required to bargain over issues related to rates of pay for new positions because these were "minor disputes" outside the scope of mandatory bargaining under RLA's Section 2 First (a) and Sixth provisions. The Supreme Court sided with the railway company in a unanimous decision stating that such matters did not fall within compulsory negotiation requirements as per RLA guidelines.

In the dissenting opinion for the case of Brotherhood of Railway & Steamship Clerks, Freight Handlers, Express & Station Employees, AFL-CIO et al. v. Florida East Coast Railway Co., Justice Goldberg argued that the majority's decision undermined labor rights and collective bargaining agreements by allowing employers to unilaterally change working conditions without negotiation or agreement from unions. He contended that this interpretation was inconsistent with both precedent and legislative intent behind federal labor laws designed to promote industrial peace through collective bargaining. The justice believed that such unilateral changes could lead to strikes and other forms of industrial unrest which these laws were intended to prevent.