Brady v. National Football League
United States Court of Appeals for the Eighth Circuit
644 F.3d 661 (2011)
After over two years of collective bargaining negotiations between the NFL (defendant) and the players' union, and facing a threatened lockout, the players voted to disclaim their union and, the same day, Brady and other players (plaintiffs) sued the NFL for antitrust violations, seeking to enjoin the lockout on the theory that losing union status ended the NFL's antitrust exemption. The district court granted a preliminary injunction against the lockout, and the NFL appealed, arguing the Norris-LaGuardia Act (NLGA) barred courts from issuing that kind of injunction in labor disputes regardless of union status.
Whether the Norris-LaGuardia Act's restrictions on court injunctions in labor disputes apply to disputes involving employees who are no longer represented by a union.