In the case of Summit Valley Industries, Inc. v. Local 112, United Brotherhood of Carpenters & Joiners of America (1981), the U.S Supreme Court ruled in favor of Summit Valley Industries. The dispute arose when a union picketed at a construction site where non-union workers were employed by Summit Valley Industries. The National Labor Relations Board (NLRB) found that this action violated section 8(b)(4)(ii)(B) of the National Labor Relations Act because it constituted an unfair labor practice to coerce neutral employers into pressuring their contractors to recognize unions. However, on appeal, both the Court of Appeals and Supreme Court disagreed with NLRB's interpretation and held that such secondary boycotts were not prohibited under federal law unless they induced or encouraged any individual employed by any person engaged in commerce or in an industry affecting commerce to engage in a strike or refusal to use goods from another employer.

In the dissenting opinion for Summit Valley Industries, Inc. v. Local 112, United Brotherhood of Carpenters & Joiners of America (1981), Justice William Rehnquist disagreed with the majority's interpretation of Section 303(b) of the Labor Management Relations Act. He argued that this section should not be interpreted to allow a company to sue a union for damages caused by an unlawful secondary boycott unless it could prove actual malice or negligence on part of the union. According to him, such an interpretation would undermine Congress' intent in passing this legislation - which was primarily aimed at preventing unions from using their economic power unfairly against neutral employers who were not directly involved in labor disputes but were indirectly affected due to their business relationships with primary employers involved in these disputes.