Budget Dress Corp. v. Joint Board of Dress & Waistmakers' Union of Greater New York
The plaintiff, a jobber in the dress industry, sought a federal injunction to prevent the collection of a New York State court money judgment. This judgment confirmed an arbitration award against the plaintiff for failing to contribute to health, welfare, and retirement funds, and for using non-union contractors, in violation of collective bargaining agreements. The plaintiff argued the demands were unlawful under the Labor Management Relations Act and that the collective agreements violated the Sherman Act. The federal court denied the plaintiff's motion, citing the Anti-Injunction Act (28 U.S.C. § 2283), the plaintiff's failure to properly litigate the illegality claims in state court, and the absence of demonstrated irreparable harm. The court found that the plaintiff had ample opportunity to raise its arguments in state court and did not carry the burden for a preliminary injunction.