HANNA MINING COMPANY ET AL. v. MARINE ENGINEERS

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Case Basics
Docket No. 
7
Petitioner 
Hanna Mining Company, National Steel Corporation, Hansand Steamship Corporation, and the Hanna Furnace Corporation
Respondent 
District 2, Marine Engineers Beneficial Association, AFL-CIO, and several officers of the Merchant Engineers Beneficial Association
Advocates
(for the petitioner)
(for the respondent)
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Facts of the Case 

Hanna Mining Company owned and operated a fleet of cargo vessels. While in negotiations for a new collecting bargaining agreement, several Hanna marine engineers expressed that they no longer wanted their union to represent them. Negotiations broke down, and the union picketed one of Hanna’s ships. This made it impossible for workers to unload the ship. Hanna petitioned the National Labor Relations Board (NLRB) to stop the picketing. The NLRB dismissed the petition because the engineers were “supervisors” as defined by the National Labor Relations Act (NLRA) and could therefore not be “employees.” The NLRA does not protect supervisors. Hanna then filed charges with the NLRB under the NLRA, alleging that the union induced a work stoppage through improper secondary pressure and engaged in improper organizational picketing. The NLRB dismissed the charges because the NLRA did not apply to unions that represent supervisors, and the union’s conduct did not exceed the bounds of lawful picketing.

Hanna sybsequently filed suit in the Wisconsin Circuit Court for Douglas County, requesting injunctive relief against further picketing and against any attempts by the union to force representation on Hanna’s engineers. The Circuit Court dismissed the suit for lack of subject matter jurisdiction. The Wisconsin Supreme Court affirmed the decision because that while the picketing was illegal under Wisconsin State law, it arguably violated the NLRA and so fell within the exclusive jurisdiction of the NLRB.

Question 

Does the NLRA preempt the state’s authority to enjoin a marine engineer union’s picketing where the marine engineers are defined as supervisors and not employees?

Conclusion 
Decision: 9 votes for Hanna Mining, 0 vote(s) against
Legal provision: National Labor Relations, as amended

No. In a 9-0 decision Justice John M. Harlan wrote for the majority. While a state may not regulate conduct arguably protected or prohibited by the NLRA, the Supreme Court found that Hanna’s engineers were supervisors, not employees, and were not covered under the Act. The NLRA did not preempt Wisconsin’s authority in this situation. The Court reversed the lower court decision and remanded the case to the Supreme Court of Wisconsin.

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HANNA MINING COMPANY ET AL. v. MARINE ENGINEERS. The Oyez Project at IIT Chicago-Kent College of Law. 04 April 2014. <http://www.oyez.org/cases/1960-1969/1965/1965_7>.
HANNA MINING COMPANY ET AL. v. MARINE ENGINEERS, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1960-1969/1965/1965_7 (last visited April 4, 2014).
"HANNA MINING COMPANY ET AL. v. MARINE ENGINEERS," The Oyez Project at IIT Chicago-Kent College of Law, accessed April 4, 2014, http://www.oyez.org/cases/1960-1969/1965/1965_7.