The U.S. Supreme Court case Retail Clerks International Association, Local Unions Nos. 128 and 633 v. Lion Dry Goods Inc., et al., revolved around the issue of whether a labor union could sue in federal court under Section 301(a) of the Labor Management Relations Act for breach of a collective bargaining agreement without having to prove diversity or jurisdictional amount. The lower courts had dismissed the suit on grounds that unions were unincorporated associations and thus not legal entities capable of suing or being sued under common law doctrine, which was applied by federal courts at that time in absence of applicable federal statutes. However, reversing these decisions, the Supreme Court held that labor organizations are indeed suable as entities for violation of contracts made by them as representatives of their members under Section 301(a). This decision expanded access to federal courts for unions seeking enforcement or interpretation of collective bargaining agreements.

In the dissenting opinion for Retail Clerks International Association, Local Unions Nos. 128 and 633 v. Lion Dry Goods, Inc., Justice Frankfurter argued that the majority's decision to allow unions to sue under Section 301 of the Labor Management Relations Act was a misinterpretation of Congressional intent. He believed that Congress intended this provision only for suits between employers and labor organizations or between different labor organizations themselves, not as a mechanism for individual employees or groups of employees to bring suit against their employer. The justice also expressed concern about potential negative impacts on collective bargaining processes if such lawsuits were permitted by individuals or small groups within larger unions without union authorization.