United Farm Workers National Union v. Sloan's Supermarkets, Inc.
Plaintiff United Farm Workers National Union (UFW) sued defendant Sloan’s Supermarkets, Inc., for misusing its Aztec Eagle certification mark, alleging violations of federal trademark and unfair competition laws. UFW sought a preliminary injunction, claiming irreparable harm to its consumer boycott of non-UFW lettuce and public deception. The court acknowledged instances of non-UFW lettuce being sold under the UFW mark but found them to be due to employee error, not deliberate malice. Sloan’s demonstrated good faith in addressing the issue. The court denied the preliminary injunction, concluding that UFW did not show immediate, irreparable injury strong enough to justify such an extraordinary remedy, and that an injunction would cause considerable harm to Sloan's business reputation given its good faith efforts.