Starbucks Corp. v. McKinney

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Supreme Court of the United States
Starbucks Corp. v. McKinney
Term: 2023
Important Dates
Argued: April 23, 2024
Decided: June 13, 2024
Outcome
Vacated and remanded
Vote
8-1
Majority
Clarence Thomas • Chief Justice John Roberts • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett
Concurring
Ketanji Brown Jackson (partial concurrence and concurring in the judgment)
Dissenting
Ketanji Brown Jackson (partial dissent)

Starbucks Corp. v. McKinney is a case that was decided by the Supreme Court of the United States on June 13, 2024, during the court's October 2023-2024 term. The case was argued before the Supreme Court of the United States on April 23, 2024.

In an 8-1 ruling, the Court vacated the United States Court of Appeals for the 6th Circuit's judgment and remanded the case for further proceedings, holding, "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., 555 U. S. 7. Pp. 4–11.."[1] Justice Clarence Thomas delivered the majority opinion of the court. Justice Ketanji Brown Jackson concurred in the judgment, concurred in part, and dissented in part. Click here for more information about the ruling.

HIGHLIGHTS
  • The issue: The case concerned the burden of proof necessary for the National Labor Relations Board to be awarded a preliminary injunction against an employer while it investigates whether the employer committed unfair labor practices. Click here to learn more about the case's background.
  • The questions presented: "Whether courts must evaluate the NLRB's requests for section 10(j) injunctions under the traditional, stringent four-factor test for preliminary injunctions or under some other more lenient standard."[2]
  • The outcome: The U.S. Supreme Court vacated the United States Court of Appeals for the 6th Circuit's judgment and remanded the case for further proceedings.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the 6th Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:


    Background

    In early January 2022, Nikki Taylor, a shift supervisor at a Starbucks in Memphis, reached out to Starbucks employees in Buffalo, New York, regarding union-organizing efforts.[3] The Buffalo employees directed her to the Union. Taylor reached out to the Union and discussed her interest in unionizing the Memphis Starbucks with her fellow employees, which included Makayla Abrams, Reaghan Hall, Nabretta Hardin, Beto Sanchez, and Kylie Throckmorton. Taylor’s discussions with the Union took place at work. Managers could overhear them and asked Taylor what the conversations were about.[4]

    On January 14, a Starbucks district manager issued two corrective-action forms to Taylor without warning. These forms were issued due to Taylor’s alleged insubordination and a dress code violation. On January 17, Taylor had a Zoom meeting with some of her coworkers and Union representatives, where they drafted a letter to Starbucks’s CEO stating their intent to unionize.[5]

    On January 18, the letter to the CEO was made public. The Memphis store closed early despite having a full staff scheduled. At around 6 p.m. that day, Taylor opened the Memphis store for a news crew. On February 8, seven employees, including union committee members, were fired due to policy violations during the press event. In June, the Memphis Starbucks voted to join the Union.[5][4]

    Between February and April 2022, the Union filed charges with the National Labor Relations Board against Starbucks for unfair labor practices. In May 2022, McKinney, a regional director of the Board, petitioned the United States District Court for the Western District of Tennessee for injunctive relief while awaiting the Board's proceedings, including the interim reinstatement of the terminated employees.[4] The district court ordered a temporary injunction, requiring that Starbucks temporarily reinstates the terminated employees. The United States Court of Appeals for the Sixth Circuit affirmed the decision.[5][4]

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether courts must evaluate the NLRB's requests for section 10(j) injunctions under the traditional, stringent four-factor test for preliminary injunctions or under some other more lenient standard.[6] ”

    Oral argument

    Audio

    Audio of oral argument:[7]



    Transcript

    Transcript of oral argument:[8]

    Outcome

    In an 8-1 ruling, the Court vacated the United States Court of Appeals for the 6th Circuit's judgment and remanded the case for further proceedings, holding, "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., 555 U. S. 7. Pp. 4–11.."[1] Justice Clarence Thomas delivered the majority opinion of the court. Justice Ketanji Brown Jackson concurred in the judgment, concurred in part, and dissented in part.


    Opinion

    In the court's majority opinion, Justice Clarence Thomas wrote:[1]

    “ The National Labor Relations Board can bring in-house enforcement proceedings against employers and labor unions for engaging in unfair labor practices. Section 10( j) of the National Labor Relations Act authorizes the Board to seek a preliminary injunction from a federal district court while these administrative enforcement proceedings take place. The question in this case is whether the traditional four-factor test for a preliminary injunction articulated in Winter v. Natural Resources Defense Council, Inc., 555 U. S.7 (2008), governs the Board’s requests under §10( j). We conclude that it does, and therefore vacate and remand.[6] ”
    —Justice Clarence Thomas

    Partial concurring and partial dissenting opinion

    Justice Ketanji Brown Jackson concurred in the judgment, concurred in part, and dissented in part.

    In her opinion, Justice Jackson wrote:[1]

    “ Today, the Court correctly applies the first step, but ignores the second. I agree with the majority that nothing in the National Labor Relations Act (NLRA) clearly strips courts of their equitable discretion to determine whether to issue a so-called §10(j) injunction. And I concur in the conclusion that we should vacate and remand for the Sixth Circuit to reevaluate this case under our traditional four-factor test for assessing requests for preliminary injunctions. But I cannot join the majority in ignoring the choices Congress has made in the NLRA about how courts should exercise their discretion in light of the National Labor Relations Board’s authority over labor disputes. Because the majority chooses the simplicity of unfettered judicial discretion over the nuances of Congress’s direction, I respectfully dissent in part.[6] ”
    —Justice Ketanji Brown Jackson


    Text of the opinion

    Read the full opinion here.


    October term 2023-2024

    See also: Supreme Court cases, October term 2023-2024

    The Supreme Court began hearing cases for the term on October 2, 2023. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 U.S. Supreme Court, Starbucks Corp. v. McKinney, decided June 13, 2024
    2. ↑ 2.0 2.1 U.S. Supreme Court, "23-367 STARBUCKS CORP. V. McKINNEY," filed January, 12, 2024
    3. ↑ U.S. Supreme Court, "STARBUCKS CORP. V. McKINNEY," granted January, 12, 2024
    4. ↑ 4.0 4.1 4.2 4.3 Casetext, "McKinney v. Starbucks Corp.," January 30, 2024
    5. ↑ 5.0 5.1 5.2 Oyez, "Starbucks Corporation v. McKinney," January 30, 2024
    6. ↑ 6.0 6.1 6.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued April 23, 2024
    8. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued April 23, 2024
    9. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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