By Jason Albright, J.D.
The case is at odds with a Fifth Circuit opinion holding that SpaceX’s action to enjoin NLRB proceedings against it did not “grow out” of the underlying labor dispute.
The Norris-LaGuardia Act strips federal district courts of jurisdiction to enjoin unfair-labor-practice proceedings, despite an employer’s contention that NLRB members and administrative law judges are unconstitutionally insulated from removal by the President, the Third Circuit held. A federal district court injunction against the NLRB’s administrative proceedings “would put a thumb on the scale for [the employer] in the underlying dispute, precisely the kind of ‘judicial interference in management-labor relations’ the Act’s anti-injunction provisions seek to prevent.” Congress did not limit the applicability of the Norris-LaGuardia Act only to cases involving identical parties to a labor dispute, and it did not create an exception for challenges to agency structure, according to the appeals court. Judge Montgomery-Reeves concurred (Spring Creek Rehabilitation and Nursing Center LLC v. NLRB, No. 24-3043 (3d Cir. Dec. 3, 2025)).
Unionized skilled nursing facility. Spring Creek Rehabilitation and Nursing Center LLC, according to the court, bought a skilled nursing facility from Amboy Nursing and Rehabilitation Center in November 2021. For years prior to the sale, Amboy maintained a collective-bargaining relationship with 1199SEIU United Healthcare Workers East, which represented the...
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