In the case of Scofield et al. v. National Labor Relations Board et al., 1968, the U.S Supreme Court ruled in favor of an employer's right to enforce work rules that were not inherently discriminatory or unfair labor practices under the National Labor Relations Act (NLRA). The dispute arose when employees at a manufacturing plant formed a union and began working slower than non-union workers, leading to disciplinary action by their employer. The union claimed this was an infringement on their rights under Section 7 of NLRA which guarantees employees "the right to self-organization, to form, join or assist labor organizations." However, the court held that while these rights are protected by law they do not include actions disrupting production or violating established company policies unless those policies themselves violate NLRA provisions. Therefore, employers can impose reasonable work rules even if they impact collective bargaining activities as long as they don't interfere with employee’s statutory rights.

In the dissenting opinion for Scofield et al. v. National Labor Relations Board et al., Justice Douglas argued that the majority's decision was an overreach of federal power into areas traditionally governed by state law and private contract. He contended that the case involved a dispute between union members, not a conflict between management and labor, which should be resolved internally within the union or through state courts if necessary. According to him, there was no evidence of unfair labor practices on part of the employer; hence it did not warrant intervention from National Labor Relations Board (NLRB). The NLRB’s involvement in this matter would set a dangerous precedent where they could interfere with any internal union affairs under guise of preventing unfair labor practices. This would undermine unions' autonomy to manage their own affairs as well as encroach upon states’ rights to regulate contracts and resolve disputes among its citizens.