Vanderbilt Law Review

First Page



The decisions of Tennessee appellate courts during the survey period have dealt extensively with the major area of controversy in current labor relations law--federal preemption.' The number of Tennessee decisions handed down which relate to injunctions restraining directly or indirectly the activities of labor organizations exceeds that in any recent comparable period. Clarification of the law applicable in the courts of the state to such activities, however, has not been achieved through these decisions. Two were reversed subsequently without opinion by the Supreme Court of the United States, and these two reversals, in turn, present serious questions as to the ultimate effect of the holdings in three additional Tennessee cases of the survey period. The problem is further complicated when consideration is given to the United States Supreme Court's affirmance of a Wisconsin injunction three weeks after the reversal of the Tennessee decisions. One of the Tennessee decisions involved picketing to achieve a purpose deemed contrary to the state's "right-to-work" statute, as did the Wisconsin case.