29 U.S.C. § 106
Section 106 · Responsibility of officers and members of associations or their organizations for unlawful acts of individual officers, members, and agents
This is the Norris-LaGuardia Act
Amended 1 time on record
Applied in 152 court decisions — leading case Sinclair Refining Co. v. Atkinson (1962)
Most recently applied in Da Silva Borges v. Bondi (July 2025)
Cases citing this section usually also cite 29 U.S.C. § 185 · 29 U.S.C. § 158 · 29 U.S.C. § 187
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
No officer or member of any association or organization, and no association or organization participating or interested in a labor dispute, shall be held responsible or liable in any court of the United States for the unlawful acts of individual officers, members, or agents, except upon clear proof of actual participation in, or actual authorization of, such acts, or of ratification of such acts after actual knowledge thereof.