The Republic Steel Corp. v. Maddox case in 1964 revolved around the issue of whether an employee could sue his employer for wrongful termination without first exhausting all available grievance procedures outlined in a collective bargaining agreement between the union and the employer. The Supreme Court ruled that under Section 301(a) of the Labor Management Relations Act, employees must exhaust any agreed-upon grievance or arbitration processes before they can file a lawsuit against their employers for breach of contract. This decision was based on promoting industrial peace and stability by encouraging private settlement through established dispute resolution mechanisms rather than resorting to court litigation immediately.

In the dissenting opinion for Republic Steel Corp. v. Maddox, Justice Goldberg argued that an employee should not be required to exhaust grievance or arbitration procedures under a collective bargaining agreement before filing a lawsuit against their employer for breach of contract. He contended that this requirement could potentially deprive employees of their rights and remedies under state law, particularly in cases where the union fails to represent them adequately during the grievance process. Furthermore, he expressed concern about forcing employees into lengthy and complex arbitration processes which may not provide adequate relief or compensation for their claims. In his view, such requirements could undermine labor peace by fostering resentment among workers who feel they have been denied access to justice.