Triangle Constr. and Maint. Corp. v. Our V.I. Labor Union

In Triangle Constr. & Maint. Corp. v. Our V.I. Labor Union, 425 F.3d 938 (11th Cir. 2005), the Court held that it lacked jurisdiction to issue an injunction against arbitration proceedings sought by a labor union in connection with a dispute.

The union had initiated arbitration proceedings with the American Arbitration Association ("AAA") regarding what it considered to be violations of the CBA/Unfair Labor Practices. The employer responded by requesting an injunction by the Northern District of Georgia to enjoin arbitration of the dispute. The district court granted the injunction and the union appealed.

The Eleventh Circuit vacated the judgment of the district court because it lacked jurisdiction to enjoin the arbitration.

The Court held that this case was one "involving or growing out of a labor dispute" and is thus covered by the Norris-LaGuardia Act (29 U.S.C. § 101 et seq) ("the Act"), which strips the federal courts of jurisdiction to issue temporary or permanent injunctions in almost all cases to which it applies. The Court found that this case does not fall within any of the limited judicial exceptions to the Act's coverage, nor is there jurisdiction under the provisions of the Act outlining the extraordinary circumstances under which a court may issue injunctive relief in a case within the Act's scope.

The Court joined five other Circuits which have examined the issue, each of which has found that a district court does not have jurisdiction to enjoin arbitration of labor disputes.