In the case of Trbovich v. United Mine Workers of America, 1971, the U.S. Supreme Court ruled that a union member has limited standing to intervene in a lawsuit brought by the Secretary of Labor against his or her union under Title IV of the Labor-Management Reporting and Disclosure Act (LMRDA). The court held that while such intervention was not generally permissible under LMRDA, it could be allowed if it did not interfere with the primary litigation or alter its nature. In this particular case, Joseph Yablonski had challenged W.A. Boyle for presidency of United Mine Workers but lost; he then alleged election irregularities and asked for an investigation which led to legal action by Secretary Hodgson against UMWA on grounds that they violated LMRDA during elections. After Yablonski's murder allegedly ordered by Boyle himself, his personal representative George Trbovich sought to intervene in Hodgson’s suit as an interested party representing rank-and-file miners' interests.

In the dissenting opinion for TRBOVICH v. UNITED MINE WORKERS OF AMERICA et al., Justice Black argued that the Secretary of Labor should be the only party allowed to sue under Title IV of the Labor-Management Reporting and Disclosure Act (LMRDA). He believed that allowing union members to intervene in such suits would undermine Congress's intent when it passed LMRDA, which was designed specifically to limit private litigation against unions. According to him, this decision could potentially open floodgates for frivolous lawsuits by disgruntled union members and weaken labor organizations' ability to function effectively. Furthermore, he emphasized that there were other avenues available for individual union members who felt their rights had been violated, including filing complaints with the Secretary or suing directly under other provisions of federal law.