Third Circuit just narrowed HR's playbook in NLRB disputes – see what changed
On December 3, 2025, the Third Circuit held district courts cannot enjoin NLRB hearings that arise from labor disputes in Spring Creek’s case under Norris-LaGuardia.
The U.S. Court of Appeals for the Third Circuit vacated a district court order and held that the Norris-LaGuardia Act removes federal district court jurisdiction to issue an injunction against National Labor Relations Board (NLRB) administrative proceedings when a case involves or grows out of a labor dispute. The ruling came in an appeal brought by Spring Creek Rehabilitation and Nursing Center LLC, which sought to block an NLRB administrative law judge from issuing a decision in an unfair labor practice case.
The dispute traces back to a New Jersey skilled nursing facility that Spring Creek purchased from Amboy Nursing and Rehabilitation Center in November 2021. For years before the sale, the workforce had been represented by 1199SEIU United Healthcare Workers East under a collective bargaining agreement that took effect in June 2017 and expired in June 2020. In August 2021, after learning of Amboy’s agreement to sell, the union filed an unfair labor practice charge with the NLRB alleging Amboy violated successor provisions tied to the sale. In the run-up to the acquisition, Spring Creek told the union it would not assume the expired agreement. In May 2023, the union amended its charge to add Spring Creek as a party.
The NLRB...
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