Starbucks Corp. v. McKinney
Facts
After employees at a Starbucks store in Memphis announced plans to unionize, several employees invited a local television news crew into the store after hours to promote their organizing effort. Starbucks investigated and fired multiple employees involved in the media event, including organizing committee members, for violating company policy. The union filed unfair labor practice charges alleging unlawful interference with employees' right to unionize and discrimination against union supporters. After the Board issued an administrative complaint, the regional Director sought a § 10(j) injunction requiring, among other things, reinstatement of the fired employees.
Issue
When the NLRB seeks a preliminary injunction under § 10(j) of the NLRA while administrative proceedings are pending, must district courts apply the traditional four-factor preliminary injunction test from Winter, or may they apply a more deferential reasonable-cause standard?
Rule
When a statute authorizes courts to grant equitable relief, courts presumptively apply traditional principles of equity unless Congress clearly commands otherwise. For § 10(j) petitions, district courts must apply the traditional Winter four-factor test: the movant must clearly show likelihood of success on the merits, likelihood of irreparable harm absent relief, that the balance of equities favors relief, and that an injunction is in the public interest.
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