In the case of Brotherhood of Railway & Steamship Clerks, Freight Handlers, Express & Station Employees v. United Air Lines Inc., 1964, the Supreme Court ruled in favor of United Airlines. The dispute arose when the union claimed that United had violated a collective bargaining agreement by unilaterally changing work rules without negotiating with them first. However, the court held that under Section 2 First and Second of the Railway Labor Act (RLA), an employer is not required to bargain over minor disputes involving interpretation or application of existing agreements but must maintain status quo until procedures for settling major disputes have been exhausted. In this case, it was determined that changes made by United were minor adjustments to working conditions rather than substantial alterations requiring negotiation with unions as per RLA provisions for major disputes.

In the dissenting opinion for Brotherhood of Railway & Steamship Clerks, Freight Handlers, Express & Station Employees v. United Air Lines Inc., Justice Harlan disagreed with the majority's interpretation of Section 2 First (a) and (b) of the Railway Labor Act. He argued that these sections do not require an employer to bargain collectively over issues related to job security or displacement allowances in case of technological advancements leading to layoffs. According to him, such matters are beyond mandatory bargaining subjects as they relate more closely to management prerogatives rather than terms and conditions of employment. Therefore, he believed that United Airlines was within its rights when it unilaterally decided on a plan regarding employee displacement due to automation without negotiating with labor unions first.