29 U.S.C. § 108
Section 108 · Noncompliance with obligations involved in labor disputes or failure to settle by negotiation or arbitration as preventing injunctive relief
This is the Norris-LaGuardia Act
Amended 1 time on record
Applied in 136 court decisions — leading case Boys Markets, Inc. v. Retail Clerks Union, Local 770 (1970)
Most recently applied in Intl Assn of Sheet Metal, Air, Rail & Trans v. Iowa Northern Railway Company (June 2022)
Cases citing this section usually also cite 29 U.S.C. § 101 · 29 U.S.C. § 107 · 45 U.S.C. § 152
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 restraining order or injunctive relief shall be granted to any complainant who has failed to comply with any obligation imposed by law which is involved in the labor dispute in question, or who has failed to make every reasonable effort to settle such dispute either by negotiation or with the aid of any available governmental machinery of mediation or voluntary arbitration.