Injunctions: Courts: Labor Law: Power of a State Court to Enjoin National Labor Relations Board Officials

The Circuit Court of Washtenaw County, Michigan, recently issued an injunction enjoining the regional officials of the National Labor Relations Board from holding a scheduled hearing in Ann Arbor, Michigan. The injunction was issued on the theory that if any unfair labor practices were being practiced by the Ann Arbor Press (a local job printer charged with violating the act) they did not affect interstate commerce and hence were not within the jurisdiction of the board. The injunction was at least temporarily effective. The hearing was not held in Ann Arbor. The regional office of the board in Detroit withdrew its complaint, but a new complaint was at once issued by the board, itself, at Washington, D. C. The hearing was accordingly held in Washington commencing May 2, 1938, presumably on the theory that the Michigan injunction had no extraterritorial effect. The regional officials of the board then moved in the Michigan court that the injunction be dissolved on the ground that the question was moot and that the state court had no jurisdiction to issue the injunction in the first place.