Amalgamated Transit Union v. Greyhound Lines, Inc.
Plaintiffs, the Amalgamated Transit Union, Local 1202, sought a temporary injunction against Greyhound Lines, arguing that Greyhound violated a New York City ordinance (Administrative Code § 22-502) by employing and transporting "strikebreakers" during a strike. Greyhound cross-moved for dismissal, contending that the local ordinance was preempted by the National Labor Relations Act (NLRA) and thus violated the Supremacy Clause. The court analyzed the federal preemption doctrine in labor disputes and concluded that the local law directly interfered with the federally recognized right of employers to hire replacement workers. Consequently, the court found both causes of action under Administrative Code § 22-502 (a) and (c) to be barred by federal preemption. The complaint was dismissed, Greyhound's cross-motion was granted, and the motion for a preliminary injunction was denied as moot.