| Venue: | SCOTUS |
| Facts: | Dispute about a collective bargaining agreement. |
| Posture: | Union sues in federal court. Dismissed for lack of subject-matter jurisdicion. Appeal. |
| Issue: | Dows the Labor Management Act of 1947 properly confer jurisdiction on the federal courts? |
| Holding: | Yes, reversed. |
| Rule: | The statute says "suits [...] may be brought in any district court of the United States." |
| Reasoning: | Congress intends for federal common law to develop in this area. Regulating union negotiations is clearly something they can do under the interstate commerce clause. This is basically protective jurisdiction (this is Burton's term, concurring). |
| Dicta: | Frankfurter (dissenting, and this is really the main thing here
in this case): It's not necessarily constitutional to grant
jurisdiction to a federal court here-- there's no diversity,
the contracts are entirely a state matter and the dispute will
be resolved under state law.
We can't augment what congress has done-- if they wanted to create a statute that gave a federal forum, they could have (drawing on Osborn. We're not able to step in and say that because they could have done so, we can consider it done. The constitution reflects a distrust of state courts when there is diversity, but when there's not, we should recognize them as perfectly adequate. |