Additional Rulings and Assessment
NLRB v. Truck Drivers Local 449 ("Buffalo Linen Supply Co.") is one of a number of Supreme Court cases stemming from the Court's 1938 decision in NLRB v. Mackay Radio & Telegraph Co.
Building on its ruling in Buffalo Linen Supply Co., the Supreme Court held in American Ship Building v. NLRB, 380 U.S. 300 (1965) that an employer may lock out its employees without violating the NLRA if a bargaining impasse has been reached and the lockout is for the purpose of applying economic pressure to support the employer's bargaining position. However, the employer cannot hire permanent replacements, only temporary ones. The high court further extended its reasoning in NLRB v. Brown Food Stores, 380 U.S. 278 (1965), holding that an employer could lock out its employees in advance of a whipsaw strike so long as the employer only utilized temporary replacements and locked out all workers (not just those who supported the union).
Buffalo Linen Supply Co. has not itself been the focus of much academic or legal analysis. However, it is often referred to in general discussions of the Court's labor relations jurisprudence. Buffalo Linen Supply Co. is one of many post-Mackay Radio rulings criticized as a Court-approved infringement on the right to strike.
Read more about this topic: NLRB V. Truck Drivers Local 449
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