Hoffmann Brothers Heating and Air Conditioning, Inc. v. National Labor Relations Board

CourtDistrict Court, E.D. Missouri
DecidedSeptember 22, 2025
Docket4:25-cv-01356
StatusUnknown

This text of Hoffmann Brothers Heating and Air Conditioning, Inc. v. National Labor Relations Board (Hoffmann Brothers Heating and Air Conditioning, Inc. v. National Labor Relations Board) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hoffmann Brothers Heating and Air Conditioning, Inc. v. National Labor Relations Board, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION HOFFMANN BROTHERS HEATING ) AND AIR CONDITIONING, INC. d/b/a ) HOFFMANN BROTHERS, ) ) Plaintiff, ) ) v. ) Case No. 4:25-cv-01356-SRC ) NATIONAL LABOR RELATIONS ) BOARD et al., ) ) Defendants. ) Memorandum and Order In late May 2025, the National Labor Relations Board filed a complaint against Hoffmann Brothers alleging unfair labor practices under the National Labor Relations Act. Doc. 2-1 at 3 (The Court cites to page numbers as assigned by CM/ECF.). That complaint gave Hoffmann Brothers notice that an administrative law judge (or ALJ) would conduct a hearing on September 23, 2025. Id. at 4. Three months later, and just thirteen days before the Board’s hearing, Hoffmann Brothers filed a complaint and a motion for a temporary restraining order seeking to enjoin the hearing. Doc. 1 at 14; doc. 3. at 1. Hoffmann Brothers alleges that the removal restrictions of Board ALJs are unconstitutional. Doc. 3 at 1. But the Norris-LaGuardia Act precludes this Court from issuing a temporary restraining order. And even if it didn’t, Hoffmann Brothers doesn’t meet its burden for a temporary restraining order. The Court therefore denies Hoffmann Brothers’ motion. Doc. 3. I. Background Hoffmann Brothers provides a “full-service commercial and residential air conditioning, heating, plumbing, and electrical contract work” in St. Louis, Missouri and in Nashville, Tennessee. Doc. 1 at ¶ 29. Local 36—on behalf of a former employee—filed a charge against

Hoffmann Brothers with the Board. Id. at ¶ 36. Almost a year later, the Board issued an administrative complaint against Hoffmann Brothers. Id. at ¶ 40. The Board alleges that a section of Hoffmann Brothers’ employee-non-compete agreement violates 29 U.S.C. § 158(a)(1). Id. at ¶¶ 37, 41. Hoffmann Brothers answered the administrative complaint. Id. at ¶¶ 42–43. Yet the Board still looks to hold a hearing on September 23, 2025. Id. at ¶ 45. So on September 10, Hoffmann Brothers filed a complaint, doc. 1, and a motion for a temporary restraining order, doc. 3, in this Court. It also requested a hearing on two days’ notice. Doc. 4. Instead of having a hearing, the Court held a conference call with counsel on September 12. Doc. 20. The Court discussed Hoffmann Brothers’ motion for a temporary restraining order and addressed various issues and arguments. Id.

During the conference call, the Court questioned Hoffmann Brothers’ timing in seeking relief in this Court only thirteen days before the Board’s hearing. Hoffmann Brothers responded that until late August it hoped to get a stipulated record for the Board’s hearing. Then on August 19, the Fifth Circuit Court of Appeals released a decision that offered a legal theory for seeking a temporary restraining order. So Hoffmann Brothers changed tack and filed its complaint and motion in this Court. Local 36 and the Board responded that these types of constitutional challenges have been percolating in federal courts for a while, and Hoffmann Brothers had three months’ notice of the hearing. Instead, they argued, this was a last-ditch effort to delay the Board’s hearing. The Court also questioned Hoffmann Brothers’ request for a hearing on its motion. Hoffmann Brothers conceded that only its client planned to testify to the harm of being summoned before an unconstitutionally insulated ALJ. And the Board stipulated to that fact. Based on its review of the entire record, the Court concludes that an evidentiary hearing is

unnecessary. The Court ordered the Board and Local 36 to submit briefing by September 16. Doc. 20. Hoffmann Brothers then sought leave to file a reply by September 18, doc. 24, which the Court granted, doc. 25. Then on September 19, the Board sought leave to file a sur-reply, doc. 27, with its sur-reply attached to the motion, doc. 27-1. And now having reviewed the entire record, the Court rules on Hoffmann Brothers’ motion. II. Discussion A. Norris-LaGuardia Act preclusion In the Norris-LaGuardia Act, Congress mandated that “[n]o court of the United States . . . shall have jurisdiction to issue any restraining order or temporary or permanent injunction in a case involving or growing out of a labor dispute,” 29 U.S.C. § 101, unless several requirements

are met, see 29 U.S.C. § 107. To determine whether the Court has the power to issue a temporary restraining order enjoining the Board’s hearing, it first must determine if this is a case “involving or growing out of a labor dispute[.]” 29 U.S.C. § 101. The Court first considers whether the Board has a labor dispute with Hoffmann Brothers. See 29 U.S.C. § 101. To do so, the Court turns to the definition of a labor dispute in 29 U.S.C. § 113(c). When construing section 113(c), the Court doesn’t write on a blank slate. The Supreme Court held that while not boundless, courts should broadly construe section 113(c). See Brady v. Nat’l Football League, 644 F.3d 661, 671 (8th Cir. 2011) (citing Jacksonville Bulk Terminals, Inc. v. Int’l Longshoremen’s Ass’n, 457 U.S. 702, 712 (1982)). The “critical element in determining whether the provisions of the Norris-LaGuardia Act apply” hinges on whether “the employer-employee relationship is the matrix of the controversy.” Jacksonville Bulk Terminals, Inc. v. Int’l Longshoremen’s Ass’n, 457 U.S. 702, 712 (1982) (citing Columbia River Packers Ass’n., Inc. v. Hinton, 315 U.S. 143, 147 (1942)).

Here, the Board has a labor dispute with Hoffmann Brothers, because this case involves a “controversy concerning terms or conditions of employment, or concerning the association or representation of persons in negotiating, fixing, maintaining, changing, or seeking to arrange terms or conditions of employment[.]” 29 U.S.C. § 113(c) (defining “labor dispute”). Local 36 alleged that Hoffmann Brothers’ employee-non-compete agreement violates 29 U.S.C. § 158(a)(1). Doc 1 at ¶¶ 37, 41. And the Board’s administrative complaint alleges that the agreement interferes, restrains, and coerces employees in employees’ exercise of their right to collective bargaining, see 29 U.S.C. § 157, an unfair labor practice under 29 U.S.C. § 158(a)(1). Doc 1 at ¶¶ 37, 41. That fits section 113’s definition of a labor dispute. 29 U.S.C. § 113(c) (“any controversy concerning . . . the association or representation of persons in negotiating,

fixing, maintaining, changing, or seeking to arrange terms or conditions of employment[.]”).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Columbia River Packers Assn., Inc. v. Hinton
315 U.S. 143 (Supreme Court, 1942)
De Beers Consolidated Mines, Ltd. v. United States
325 U.S. 212 (Supreme Court, 1945)
Renegotiation Board v. Bannercraft Clothing Co.
415 U.S. 1 (Supreme Court, 1974)
Elrod v. Burns
427 U.S. 347 (Supreme Court, 1976)
Brady v. National Football League
644 F.3d 661 (Eighth Circuit, 2011)
Dataphase Systems, Inc. v. C L Systems, Inc.
640 F.2d 109 (Eighth Circuit, 1981)
Devose v. Herrington
42 F.3d 470 (Eighth Circuit, 1994)
Entergy Arkansas, Inc. v. State Of Nebraska
210 F.3d 887 (Eighth Circuit, 2000)
CDI Energy Services, Inc. v. West River Pumps, Inc.
567 F.3d 398 (Eighth Circuit, 2009)
General Motors Corp. v. Harry Brown's, LLC
563 F.3d 312 (Eighth Circuit, 2009)
Grace Co. v. Williams
96 F.2d 478 (Eighth Circuit, 1938)
Hubbard Feeds, Inc. v. Animal Feed Supplement, Inc.
182 F.3d 598 (Eighth Circuit, 1999)
Jason Powell v. Roxann Ryan
855 F.3d 899 (Eighth Circuit, 2017)
Cory Sessler v. City of Davenport, Iowa
990 F.3d 1150 (Eighth Circuit, 2021)
Collins v. Yellen
594 U.S. 220 (Supreme Court, 2021)
Tod Tumey v. Mycroft AI, Inc.
27 F.4th 657 (Eighth Circuit, 2022)
West v. Bergland
611 F.2d 710 (Eighth Circuit, 1979)
H&R Block, Inc. v. Block, Inc.
58 F.4th 939 (Eighth Circuit, 2023)
Evan Ng v. Board of Regents of the U of M
64 F.4th 992 (Eighth Circuit, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
Hoffmann Brothers Heating and Air Conditioning, Inc. v. National Labor Relations Board, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hoffmann-brothers-heating-and-air-conditioning-inc-v-national-labor-moed-2025.