Starbucks v. McKinney
In brief
The Sixth Circuit's decision was vacated, and Section 10(j) injunction requests must be judged under the traditional four-factor preliminary-injunction test.
- Where it stands
- Decided
Decided 9-0 · June 13, 2024 · Opinion by Justice Thomas
- What it’s about
- The Court ruled for Starbucks, holding that federal courts considering the National Labor Relations Board’s requests for temporary injunctions under Section 10(j) of the National Labor Relations Act must use the usual four-factor test for preliminary injunctions.
- Who it affects
- The decision makes the Board meet the same preliminary-injunction test as other parties seeking emergency court orders. For example, an employer facing a requested order during a labor dispute can challenge whether the Board meets all four factors.
Summary: written with AI from the case record.
What it's about
The Court vacated the Sixth Circuit’s decision and sent the case back for reconsideration under that standard.
The decision resolves a split among lower courts over the standard for temporary labor-law injunctions sought by the National Labor Relations Board.
Question presented
What test must courts use to evaluate requests for injunctions under Section 10(j) of the National Labor Relations Act?
What the Court decided
Holding
When considering the NLRB’s request for a preliminary injunction under §10( j), district courts must apply the traditional four factors articulated in Winter v. Natural Resources Defense Council, Inc. , 555 U. S. 7. 77 F. 4th 391, vacated and remanded.
- Result
- Vacated
The vote
From the opinions
“district courts must apply the traditional four factors articulated in Winter v. Natural Resources Defense Council, Inc.”
What's next
The case returns for reconsideration under the four-factor standard. Lower courts must use that standard when the Board seeks a temporary Section 10(j) injunction.
Docket activity
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More questions
- What did the Supreme Court rule in Starbucks v. McKinney?
- The Court said federal courts must use the traditional four-factor test when the National Labor Relations Board seeks a Section 10(j) preliminary injunction.
- Who won Starbucks v. McKinney?
- Starbucks won. The Court vacated the Sixth Circuit's decision and sent the case back for reconsideration.
- What does Starbucks v. McKinney mean for employers?
- Employers may contest whether the Board satisfies all four traditional factors before a court issues a temporary labor-law injunction.
- Is the four-factor preliminary-injunction test still the law after Starbucks v. McKinney?
- Yes. The Court required district courts to apply that traditional test to the Board's Section 10(j) injunction requests.
- What happens next in Starbucks v. McKinney?
- The lower court must reconsider the request using the traditional four-factor standard. Other lower courts must follow the same approach.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.