Smart & Final Logistics v. Teamsters Local 630 CA4/3

CourtCalifornia Court of Appeal
DecidedSeptember 4, 2025
DocketG064544
StatusUnpublished

This text of Smart & Final Logistics v. Teamsters Local 630 CA4/3 (Smart & Final Logistics v. Teamsters Local 630 CA4/3) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Smart & Final Logistics v. Teamsters Local 630 CA4/3, (Cal. Ct. App. 2025).

Opinion

Filed 9/4/25 Smart & Final Logistics v. Teamsters Local 630 CA4/3

NOT TO BE PUBLISHED IN OFFICIAL REPORTS

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION THREE

SMART & FINAL LOGISTICS LLC,

Plaintiff and Respondent, G064544

v. (Super. Ct. No. CVRI2306292)

TEAMSTERS LOCAL 630, OPINION

Defendant and Appellant.

Appeal from an order of the Superior Court of Riverside County, Eric A. Keen, Judge. Affirmed. Bush Gottlieb, Julie Gutman Dickinson, Jason Wojciechowski and Luke Taylor for Defendant and Appellant. Goodwin Procter, Matthew P. Kanny, Andrew Kim and Allyson M. McCain for Plaintiff and Respondent. In 2024, the trial court issued a preliminary injunction enjoining defendant Teamsters Local 630 (Union), and those acting in concert with it, from, inter alia, (1) blocking ingress to and egress from the entrance of a distribution center owned by plaintiff Smart & Final Logistics LLC (Smart & Final); and (2) engaging in violent acts or threatening violence against, or causing property damage to Smart & Final, its employees or its business partners. The Union challenges the order issuing the preliminary injunction, arguing insufficient evidence supports the court’s statutorily required findings there existed a threat of unlawful future conduct that will be committed unless restrained (Lab. Code, § 1138.1, subd. (a)(1)); police officers were unable or unwilling to furnish adequate protection (id., § 1138.1, subd. (a)(5)); and Smart & Final made every reasonable effort to settle the parties’ dispute (id., § 1138.2).1 The Union also argues the National Labor Relations Board (NLRB) has exclusive jurisdiction over the matter and therefore the trial court lacked jurisdiction to issue the preliminary injunction in the first place. For the reasons we explain, we reject the Union’s arguments and affirm. FACTS Smart & Final operates a distribution center in Riverside, California (the Facility). The Union is a labor organization which represents a section of Smart & Final employees and has been in contract negotiations with Smart & Final in connection with a labor dispute since July 26, 2023.

1 All further code references are to the Labor Code unless

otherwise specified.

2 From July to November 2023, Smart & Final met with the Union on seven different days to negotiate a contract. They did not reach an agreement.2 In the early morning of November 1, 2023, the Union began a strike at which time employees and members of the Union, a Union officer, and others started picketing the Facility. “The Union and its members were positioned in the cul-de-sac in front of the driveway entrance to the Facility and generally walked back and forth in front of the entrance to the Facility to picket”; that was the Facility’s single point of access, ingress, and egress. Dozens of picketers formed a human barricade preventing trucks and cars from entering or leaving the Facility. On November 1, 2023, Smart & Final’s counsel sent an e-mail to the Union asking it to “cease and desist from blocking, obstructing, and or delaying vehicular or pedestrian ingress and egress to the Commerce and Riverside distribution centers immediately” and to “not reinitiate or continue any such conduct in the future.” On November 2, 2023, the Union received another e-mail from Smart & Final’s counsel which attached the November 1 e-mail. Neither the Union nor its counsel or anyone affiliated with the Union responded to either e-mail. Smart & Final vice-president Sue Mullins sent a letter dated November 3, 2023 to the chief of police of the Riverside Police Department in which Mullins described the Union’s activities at the Facility. She concluded her letter by stating: “Please act. Please direct the Riverside Police Department to stop—and keep stopped—the [U]nion’s blatant violation of the

2 Smart & Final and the Union thereafter met 15 additional days

before the issuance of the instant preliminary injunction, but they remained unable to reach agreement.

3 law. Stop the blocking. Stop the false imprisonment of our employees and your constituents. Stop the interruption of food to our communities.” On November 6, 2023, the assistant city attorney responded to Mullins by sending a letter stating the Riverside Police Department was not responsible for taking action to stop the picketing and that if Smart & Final believed the Union’s actions were unlawful, it should consult with legal counsel “for assistance with potential civil remedies that may be available through the appropriate court as the police are not the proper forum for adjudicating labor disputes.” The police did not thereafter instruct the Union to stop the conduct Smart & Final considered to be unlawful blocking activity. On November 17, 2023, Smart & Final’s counsel sent an e-mail to the Union’s counsel and others stating in part: “The Union’s blocking activity must immediately and permanently stop. Its violence and threats of violence against Smart & Final employees and business affiliates must also immediately and permanently stop. We need written assurance from the Union that the Union’s (including its allies, affiliates, and supporters under its control, direction, or influence) continued misconduct as described herein will permanently end. Thus, by no later than 3:00 [p.m.] PT on Monday, November 20, 2023, we hereby demand that the Union agree, in writing via e[-]mail . . . that it will cease and desist from and permanently stop and not resume its blocking activity and other unlawful conduct described above at the Facilities . . . . Absent such written confirmation at that date/time, [Smart & Final] will take appropriate action.” (Boldface and underscoring omitted.)

4 The following day, the Union responded, denying it had engaged in unlawful conduct and demanding that Smart & Final immediately return all striking workers to their jobs without condition. The picketing activity occurred around the clock every day from November 1, 2023 until November 17, 2023. The Union not only blocked the Facility’s sole point of access, ingress, and egress during that time, but its activity involved violent acts, threats of violence, and damage to property. PROCEDURAL HISTORY I. THE COMPLAINT In November 2023, Smart & Final filed a verified complaint for a preliminary and permanent injunction, declaratory relief, and damages. The complaint contained claims for private nuisance, public nuisance, intentional interference with prospective economic relations, preliminary and permanent injunctive relief, and declaratory relief. II. SMART & FINAL FILES THE MOTION FOR A PRELIMINARY INJUNCTION Shortly after filing the complaint, on November 27, 2023, Smart & Final filed a motion for a preliminary injunction in which it sought an order enjoining the Union from, directly or indirectly, engaging or participating in conduct consisting of: (1) blocking ingress to, egress from, and access to the Facility; (2) obstructing the free passage of individuals or vehicles entering and leaving the Facility, including on the public street in front of the Facility; (3) engaging in violent acts or threats of violence against Smart & Final, its employees, or business partners; (4) causing property damage to Smart & Final, its employees, or business partners; and

5 (5) committing any other unlawful and disruptive acts the court deemed appropriate.

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Bluebook (online)
Smart & Final Logistics v. Teamsters Local 630 CA4/3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smart-final-logistics-v-teamsters-local-630-ca43-calctapp-2025.