Amazon.com Services, LLC v. National Labor Relations Board

Summary

The Ninth Circuit affirmed the district court’s denial of Amazon.com Services, LLC’s motion for a preliminary injunction seeking to halt National Labor Relations Board proceedings. The court held that the Norris-LaGuardia Act barred the requested injunction because the case involved or grew out of a labor dispute concerning the representation and employment terms of Amazon delivery drivers. The court rejected Amazon’s argument that its constitutional challenges to the Board’s structure were too attenuated from the underlying labor dispute.

Holdings

1. The Norris-LaGuardia Act applies because the case involves or grows out of a labor dispute. Section 113(a) imposes separate requirements for the pending case and the underlying labor dispute, and both requirements were satisfied.
2. No. The pending case need only involve or grow out of an underlying labor dispute; it need not itself be a labor dispute or directly concern terms or conditions of employment.
3. The Thunder Basin inquiry does not control because the Norris-LaGuardia Act expressly bars federal courts from issuing injunctions in cases involving or growing out of labor disputes.

Questions Presented

1. Whether the Norris-LaGuardia Act deprives federal courts of power to issue a preliminary injunction stopping NLRB proceedings when the underlying proceedings arise from an unfair-labor-practice dispute between an employer and a union.
2. Whether the Norris-LaGuardia Act requires the pending constitutional challenge itself to be a direct dispute between an employer and employees or to concern employment terms or conditions.
3. Whether the Thunder Basin doctrine governs the jurisdictional question when the Norris-LaGuardia Act expressly bars injunctive relief.

Disposition

affirmed