California Pacific Medical Center

United States Court of Appeals for the Ninth Circuit · 1994 · Labor Law

19 F.3d 449 (1994)

Updated July 19, 2026

Labor LawNLRASection 10(j) injunctionsPreliminary injunctions§ 10(j)preliminary injunctionreasonable causejust and proper

Facts

Children’s Hospital of San Francisco and Pacific Presbyterian Medical Center merged into California Pacific Medical Center, with Children’s as the surviving corporation. Before the merger, the California Nurses Association represented 568 registered nurses at Children’s, while PPMC’s 802 registered nurses were unrepresented. On the date of the merger, CPMC informed CNA that it would no longer recognize the union because CNA did not represent a majority of nurses at the combined facility, and CNA filed an unfair labor practice charge. Eight months later, the Regional Director sought a § 10(j) injunction to restore CNA’s recognition and the pre-merger status quo pending the Board’s resolution of the charge.

Issue

What standard should district courts apply when deciding whether to grant temporary relief under NLRA § 10(j)? Specifically, must courts apply a separate reasonable-cause inquiry, or should they determine only whether relief is just and proper under traditional equitable principles informed by the purposes of § 10(j)?

Rule

In deciding a § 10(j) petition, a district court should not apply a separate reasonable-cause inquiry. The court must determine only whether the requested relief is just and proper by applying traditional equitable criteria—likelihood of success on the merits, possibility of irreparable injury, balance of hardships, and the public interest—viewed in light of § 10(j)'s purposes of protecting the integrity of collective bargaining and preserving the Board's remedial power pending adjudication.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, the NLRB's Regional Director petitions for a § 10(j) injunction against Desert Valley Components, alleging it unlawfully refused to bargain with a union after a restructuring. The district judge finds the Board's theory is substantial and nonfrivolous, then grants the injunction without separately analyzing likelihood of success, irreparable injury, balance of hardships, or the public interest.

On appeal in the Ninth Circuit, what is the strongest argument against the injunction?

Explanation. The majority held that § 10(j) contains no separate reasonable-cause inquiry. A district court must decide only whether relief is 'just and proper' by applying traditional equitable criteria: likelihood of success, irreparable injury, balance of hardships, and public interest, viewed in light of § 10(j)'s purposes. Granting relief based only on a finding that the Board's theory is nonfrivolous uses the wrong standard.