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.
The Supreme Court addressed the standard district courts must apply when considering the National Labor Relations Board's request for a preliminary injunction under § 10(j) of the National Labor Relations Act. The Court emphasized the need to apply the traditional four-factor test for equitable relief, as articulated in Winter v. Natural Resources Defense Council, Inc. The decision vacated and remanded the Sixth Circuit's affirmation of the district court's injunction.
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 equitable relief when considering § 10(j) petitions from the NLRB.
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 Administrative Law is relevant to Starbucks Corp. v. McKinney
The case involves the application of traditional equitable principles in the context of agency authority under the National Labor Relations Act.
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 Judicial Review is relevant to Starbucks Corp. v. McKinney
The Court's decision addresses the standard district courts must apply when reviewing requests for preliminary injunctions under § 10(j) of the NLRA.
Syllabus excerpt (verbatim)Absent a clear command from Congress, then, courts must adhere to the traditional four-factor test articulated in Winter.
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Why Remedies and Relief is relevant to Starbucks Corp. v. McKinney
The case discusses the limits and application of equitable relief in the form of preliminary injunctions.
Syllabus excerpt (verbatim)Section 10(j)'s statutory directive to grant injunctive relief when the district court 'deems' it 'just and proper' does not jettison the normal equitable rules.
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 traditional rule is that a plaintiff seeking a preliminary injunction must make a clear showing that 'he is likely to succeed on the merits.'
Section 10(j)'s statutory context does not compel this watered-down approach to equity.
