Starbucks Corp. v. McKinney
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Starbucks Corp. v. McKinney and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Starbucks Corp. v. McKinney.
The Supreme Court vacated and remanded the decision of the Sixth Circuit, clarifying that district courts must apply the traditional four-factor test for preliminary injunctions when considering requests under § 10(j) of the National Labor Relations Act. The Court rejected the Sixth Circuit's reasonable-cause standard, emphasizing adherence to established equitable principles. This decision impacts how courts evaluate the National Labor Relations Board's petitions for temporary relief during administrative proceedings.
Holding
The single most important “bottom line” of what the Court decided in Starbucks Corp. v. McKinney.
The Court held that district courts must apply the traditional four-factor test for preliminary injunctions articulated in Winter v. Natural Resources Defense Council, Inc., when considering § 10(j) requests.
Constitutional Concepts
These are the Constitution-related themes that appear in Starbucks Corp. v. McKinney. Click a concept to see other cases that involve the same idea.
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Why Administrative Law is relevant to Starbucks Corp. v. McKinney
The case involves the authority of the National Labor Relations Board and the application of traditional equitable principles by courts when considering requests for preliminary injunctions under § 10(j).
Syllabus excerpt (verbatim)When Congress empowers courts to grant equitable relief, there is a strong presumption that courts will exercise that authority in a manner consistent with traditional principles of equity.
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Why Judicial Review is relevant to Starbucks Corp. v. McKinney
The Court's decision involves the power of federal courts to review and apply traditional equitable principles in the context of administrative agency requests for injunctions.
Syllabus excerpt (verbatim)Absent a clear command from Congress, then, courts must adhere to the traditional four-factor test articulated in Winter.
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Why Remedies and Relief is relevant to Starbucks Corp. v. McKinney
The case addresses the limits and standards for granting preliminary injunctions, which are a form of judicial relief.
Syllabus excerpt (verbatim)Section 10(j)'s statutory directive to grant injunctive relief when the district court 'deems' it 'just and proper' does not jettison the normal equitable rules.
Key Quotes
Short excerpts from the syllabus in Starbucks Corp. v. McKinney that support the summary and concepts above.
When considering the NLRB's request for a preliminary injunction under § 10(j), district courts must apply the traditional four factors articulated in Winter v. Natural Resources Defense Council, Inc.
Section 10(j)'s statutory directive to grant injunctive relief when the district court 'deems' it 'just and proper' does not jettison the normal equitable rules.
Deference to what is 'nothing more than an agency's convenient litigating position' is 'entirely inappropriate.'