Labor Law – Objects of Union Action – Organization of Managers of Retail Chain Stores as Proper Object

The owner and operator of retail food stores located throughout the nation brought action to enjoin strike activities by the defendant union, which sought recognition as bargaining agent for managers and clerks in the local stores. Both clerks and store managers had been members of the defendant local unions since 1937, and the latter, acting under certification as bargaining representative for both groups of employees under the National Labor Relations Act, had negotiated contracts with the plaintiff covering managers and clerks continuously since that time. Upon the refusal of the plaintiff to include the store managers in the contract, or to recognize the clerks’ unions as the representatives of the store managers, the union struck and the present action was commenced. Held, with a dissenting opinion, that the union activities in seeking recognition as bargaining agent for local retail store managers, who were supervisory employees, were not reasonably related to any legitimate interest of organized labor, were not in furtherance of any proper labor objective, and, as a matter of sound public policy, were enjoinable within equity jurisdiction of the court. Safeway Stores, Inc. v. Retail Clerks International Assn., 41 Cal. (2d) 567, 261 P. (2d) 721 (1953)