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.
In Starbucks Corp. v. McKinney, the Supreme Court addressed the standards for granting preliminary injunctions under § 10(j) of the National Labor Relations Act. The case arose after Starbucks fired employees involved in a unionizing effort, leading to a complaint by the National Labor Relations Board (NLRB). The District Court and the Sixth Circuit applied a two-part test to grant an injunction for reinstatement. The Supreme Court vacated and remanded, emphasizing the need for courts to apply the traditional four-factor test for equitable relief as articulated in Winter v. Natural Resources Defense Council.
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 when considering requests under § 10(j) of the National Labor Relations Act.
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 Due Process is relevant to Starbucks Corp. v. McKinney
The case involves the procedural requirement of applying traditional equitable principles in granting preliminary injunctions, which is related to due process.
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 Separation of Powers is relevant to Starbucks Corp. v. McKinney
The case discusses the roles of the judiciary and an administrative agency, highlighting the separation of powers between courts and the NLRB.
Syllabus excerpt (verbatim)The Board suggests that district courts risk supplanting its adjudicatory authority by conducting an independent assessment of the merits and equitable factors.
Key Quotes
Short excerpts from the syllabus in Starbucks Corp. v. McKinney that support the summary and concepts above.
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.
The Board's attempt to salvage the reasonable-cause standard using statutory context thus fails.
Deference to what is 'nothing more than an agency's convenient litigating position' is 'entirely inappropriate.'