Spring Creek Rehabilitation and Nursing Center LLC v. NLRB

Summary

The United States Court of Appeals for the Third Circuit held that the Norris-LaGuardia Act strips a district court of jurisdiction to enjoin NLRB administrative proceedings arising from an underlying labor dispute, including proceedings challenged on constitutional grounds. The court vacated the district court’s order denying preliminary injunctive relief and remanded for further proceedings. Judge Montgomery-Reeves concurred, concluding that Spring Creek lacked Article III standing because it had not shown an injury caused by the NLRB’s allegedly unconstitutional removal protections.

Holdings

1. An action seeking to enjoin NLRB administrative proceedings on constitutional grounds grows out of an underlying labor dispute when the proceedings concern whether the employer committed unfair labor practices by refusing to bargain with the employees' union.
2. No recognized exception to the Norris-LaGuardia Act applies because the case does not involve arbitration and Spring Creek's requested injunction is not based on federal statutory rights requiring reconciliation with the Act.
3. The Norris-LaGuardia Act stripped the district court of jurisdiction to issue an injunction against the NLRB in this posture.

Questions Presented

1. Whether the Norris-LaGuardia Act deprives a federal district court of jurisdiction to enjoin NLRB administrative proceedings when the action challenging the agency's constitutional structure grows out of an underlying labor dispute.
2. Whether a judicially created exception to the Norris-LaGuardia Act applies to Spring Creek's constitutional challenge.
3. Whether the court could reach the Article III standing issue raised in the concurrence.

Disposition

vacated