U.S Supreme Court Issues Major Labor and Employment Law Opinion in the Case of Starbucks Corp. v. McKinney

On June 13, 2024, a decision was rendered in the Supreme Court of the United States in the case of Starbucks Corp. v. McKinney.

The case pertains to the following: “After several Starbucks employees announced plans to unionize, they invited a news crew from a local television station to visit the store after hours to promote their unionizing effort” and “Starbucks fired multiple employees involved with the media event for violating company policy.” See Starbucks Corp. v. McKinney, No. 23-367, 2024 U.S. LEXIS 2603, at *1 (June 13, 2024.) “The National Labor Relations Board filed an administrative complaint against Starbucks alleging that it had engaged in unfair labor practices” and “[t]he Boards regional Director then filed a petition under 10( j) of the National Labor Relations Act seeking a preliminary injunction for the duration of the administrative proceedings that would, among other things, require Starbucks to reinstate the fired employees.” Id.

As to the District Court, it “assessed whether the Board was entitled to a preliminary injunction by applying a two-part test that asks whether there is reasonable cause to believe that unfair labor practices have occurred, and whether injunctive relief is just and proper.” See
Starbucks Corp. v. McKinney, No. 23-367, 2024 U.S. LEXIS 2603, at *1-2 (June 13, 2024) (citing McKinney v. Ozburn-Hessey Logistics, LLC, 875 F. 3d 333, 339.) “Applying this standard, the District Court granted the injunction, and the Sixth Circuit affirmed.” See Starbucks Corp. v.
McKinney, No. 23-367, 2024 U.S. LEXIS 2603, at *2 (June 13, 2024.)

The Supreme Court held that “[w]hen considering the NLRBs 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. Pp. 4-11.” See Starbucks Corp.
v. McKinney, No. 23-367, 2024 U.S. LEXIS 2603, at *2 (June 13, 2024.)

The Court stated that “Section 10(j) authorizes a federal district court to grant . . . such temporary relief . . . as it deems just and proper during the pendency of the Boards administrative proceedings.” See Starbucks Corp. v. McKinney, No. 23-367, 2024 U.S. LEXIS 2603, at *9 (June 13, 2024) (citing 160(j).) Moreover, “[w]hen Congress empowers courts to grant equitable relief, there is a strong presumption that courts will exercise that authority in a manner consistent with traditional principles of equity.” See Starbucks Corp. v. McKinney, No. 23-367, 2024 U.S. LEXIS 2603, at *9 (June 13, 2024.) “For preliminary injunctions, the four criteria identified in Winter encompass the relevant equitable principles” and “[n]othing in 10(j) displaces the presumption that those traditional principles govern.” See Starbucks Corp. v. McKinney, No. 23- 367, 2024 U.S. LEXIS 2603, at *10 (June 13, 2024.) Thus, the Court “conclude[d] that district courts must use the traditional four-part test when evaluating the Boards request for a preliminary injunction under 10(j).” See Starbucks Corp. v. McKinney, No. 23-367, 2024 U.S. LEXIS 2603, at *10 (June 13, 2024.)

The Court went on to state that “[t]he default rule is that a plaintiff seeking a preliminary injunction must make a clear showing that he is likely to succeed on the merits, that he is likely to suffer irreparable harm in the absence of preliminary relief, that the balance of equities tips in his
favor, and that an injunction is in the public interest.” See Starbucks Corp. v. McKinney, No. 23- 367, 2024 U.S. LEXIS 2603, at *10 (June 13, 2024) (citing Winter, 555 U. S., at 20, 22.) The Court indicated that “[w]hen interpreting a statute that authorizes federal courts to grant preliminary injunctions, we do not lightly assume that Congress has intended to depart from established principles.” See Starbucks Corp. v. McKinney, No. 23-367, 2024 U.S. LEXIS 2603, at *11 (June 13, 2024) (citing Romero-Barcelo, 456 U. S., at 313; see also Porter v. Warner Holding Co., 328 U. S. 395, 398 (1946).) The Court indicated that it “has consistently employed this presumption when interpreting a wide variety of statutes that authorize preliminary and permanent injunctions.” See Starbucks Corp. v. McKinney, No. 23-367, 2024 U.S. LEXIS 2603, at *11 (June 13, 2024) (citations omitted.) Consequently, the Court indicated that “absent a clear command from Congress, courts must adhere to the traditional four-factor test.” See Starbucks Corp. v. McKinney, No. 23-367, 2024 U.S. LEXIS 2603, at *11 (June 13, 2024.) The Court indicated that “because nothing in 10(j)s text overcomes the presumption that traditional equitable principles govern, district courts considering the Boards request for a preliminary injunction must apply the Winter framework, which embodies those traditional principles.” See Starbucks Corp. v. McKinney, No. 23-367, 2024 U.S. LEXIS 2603, at *14 (June 13, 2024.)

Ultimately the Court held that “district courts must apply the traditional four factors articulated in Winter when considering the Boards requests for a preliminary injunction under 10(j).” See Starbucks Corp. v. McKinney, No. 23-367, 2024 U.S. LEXIS 2603, at *19 (June 13,
2024.)

Justice Jackson filed an opinion concurring in part, concurring in the judgment, and dissenting in part.

If you have any further questions or concerns as to how this case may affect your company’s workplace policies and procedures, we, at Thomas Paschos & Associates, P.C. would be glad to speak with you and review your workplace policies and procedures. One of our attorneys specializing in this field can speak with you today about our services. Contact Thomas Paschos & Associates, P.C. for more information. We can be reached at 856-354-1900 or 267-205-2444. You can also contact Thomas Paschos, Esq. TPaschos@pascholaw.com