Glacier Northwest, Inc. v. International Brotherhood of Teamsters

On June 1, 2023, the Supreme Court of the United States decided Glacier Northwest, Inc. v. International Brotherhood of Teamsters Local Union No. 174. Glacier Northwest, a ready-mix concrete company, sued the union in Washington state court after truck drivers went on strike while their mixing drums were filled with wet concrete. The drivers left the trucks running and did not empty the concrete, creating an imminent risk that the concrete would harden and damage the vehicles. The company alleged intentional destruction of property and sought tort damages. The Washington Supreme Court held that the National Labor Relations Act preempted the state claim because the strike conduct was arguably protected. The U.S. Supreme Court reversed, holding that the union had failed to take reasonable precautions to protect the employer's property from imminent danger, so the conduct was arguably unprotected and the state tort claim could proceed. The decision clarified the limits of NLRA preemption and union strike protections.

The U.S. Supreme Court reversed the Washington Supreme Court and remanded, holding that the state tort claim was not preempted because the union's alleged conduct was arguably unprotected under the NLRA.

Whether the National Labor Relations Act preempts a state tort claim against a labor union for intentional damage to an employer's property during a strike when the union allegedly failed to take reasonable precautions to prevent imminent harm.

The ruling narrowed federal labor preemption and made clear that unions may face state tort liability for intentionally destructive strike conduct, altering the risk calculus for labor disputes and reinforcing employer property rights.