National Labor Relations Board v. Brown

The respondents, who are members of a multiemployer bargaining group, locked out their employees in response *280to a whipsaw strike against another member of the group. They and the struck employer continued operations with temporary replacements. The National Labor Relations Board found that the struck employer’s use of temporary replacements was lawful under Labor Board v. Mackay Radio & Telegraph Co., 304 U. S. 333, but that the respondents had violated §§8(a)(1) and (3) of the National Labor Relations Act1 by locking out their regular employees and using temporary replacements to carry on…