Spring Creek Rehabilitation and Nursing Center LLC v. NLRB
Split Score
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Case Summary
Disposition
Vacated
Spring Creek sought a preliminary injunction to block an NLRB unfair-labor-practice hearing, claiming the Board’s administrative law judges are unconstitutionally insulated from presidential removal. The Third Circuit held that the Norris-LaGuardia Act removes district-court jurisdiction to issue such injunctions because the action ‘grows out of’ an underlying labor dispute, vacating the district court’s denial of an injunction and remanding with instructions to dismiss for lack of jurisdiction.
Circuit Split Identified
Legal Issue
Whether the Norris-LaGuardia Act strips federal district courts of jurisdiction to enjoin ongoing NLRB administrative proceedings when the employer raises constitutional challenges to the agency’s structure.
Circuit Positions
Norris-LaGuardia Act applies and strips district-court jurisdiction over suits seeking to halt NLRB proceedings, even when the plaintiff alleges constitutional defects in the agency’s structure.
Norris-LaGuardia Act does not apply to employer suits challenging NLRB administrative proceedings on constitutional grounds; district courts retain jurisdiction.
Conflict Summary
The Third, Sixth, and Seventh Circuits hold that such suits ‘involve or grow out of’ a labor dispute, so the Norris-LaGuardia Act’s anti-injunction provisions divest the district court of jurisdiction. The Fifth Circuit, in Space Exploration Techs. Corp. v. NLRB, takes the opposite view, concluding the Act does not apply because the action is not between employer and employees and concerns purely constitutional questions, thereby leaving district-court jurisdiction intact.