Case Citator › Sinclair Refining Co. v. Atkinson

Sinclair Refining Co. v. Atkinson

Is it still good law? What later courts have actually done to this case.

Overruled
Court
Supreme Court of the United States
Citation
370 U.S. 195
Decided
Confirmed treatments
2
Flagged citations read
76 of 76
Citing cases (total)
376
Treatment dates
1970–2020
Overruled
A reviewed court has overruled this case. Sinclair Refining Co. v. Atkinson has been fully reviewed: all 76 flagged citations are accounted for, 75 had readable text citing Sinclair, and the 2 confirmed treatments are listed below. The Supreme Court expressly overruled Sinclair's Norris-LaGuardia anti-injunction holding in Boys Markets, Inc. v. Retail Clerks Union, Local 770.
More on how this was screened

Decades later, Donegal Services, LLC v. International Union of Operating Engineers Local 150, AFL-CIO declined to follow a separate Sinclair dictum concerning a private right of action under § 302 of the Labor Management Relations Act. The other readable citing opinions applied a surviving Sinclair proposition or reported Boys Markets' act.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

376 later cases cite Sinclair Refining Co. v. Atkinson; 76 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Sinclair Refining Co. v. Atkinson?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled

  • The Supreme Court overruled Sinclair's holding that the Norris-LaGuardia Act bars a narrowly conditioned injunction against a strike over a grievance the parties are contractually bound to arbitrate.

    Boys Markets, Inc. v. Retail Clerks Union, Local 770 · Supreme Court of the United States · filed

    Having concluded that Sinclair was erroneously decided and that subsequent events have undermined its continuing validity, we overrule that decision and reverse the judgment of the Court of Appeals.
    Read the full opinion on CourtListener →

Declined to follow

  • The court declined to follow Sinclair's dictum that § 302 permits private injunction suits, finding the dictum unexplained and holding that § 302 creates no private right of action.

    Donegal Services, LLC v. International Union of Operating Engineers Local 150, AFL-CIO · N.D. Ill. · filed

    Plaintiffs also rely on dictum in Sinclair Refining Co. v. Atkinson, 370 U.S. 195, 205 n.19 (1962), overruled in part on other grounds by Boys Markets, Inc. v. Retail Clerks Union, Local 770, 398 U.S. 235 (1970), to the effect that § 302 “expressly permit[s] suits for injunctions previously proscribed by the Norris-LaGuardia Act to be brought in the federal courts by private litigants.” The Court in Mulhall did not expressly address whether a private right of action exists under § 302. As for the Sinclair Refining dictum, it appears in a footnote, without analysis. Moreover, Justice Breyer, in dissenting from the dismissal of the writ of certiorari in Mulhall as improvidently granted, questioned the “legal status” of the Sinclair Refining dictum “in light of the Court’s more restrictive views on private rights of action in recent decades.” Unite Here Local 355 v. Mulhall, 571 U.S. 83, 85 (2013) (Breyer, J., dissenting). It is this Court’s view, based on the persuasive reasoning of Ohlendorf, that § 302 does not create a private right of action.
    Read the full opinion on CourtListener →

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