New York Telephone Co. v. Communications Workers of America
In New York Telephone Co. v. Communications Workers of America, 445 F.2d 39, 48 (2d Cir.1971), a temporary restraining order barred the unions "from engaging in ... any strike, work stoppage, boycott of overtime work, slowdown or any other form of interference with the business of plaintiff." Id. at 43.
In the interest of reaching a settlement, the parties agreed to extend this order indefinitely. Id. An agreement was reached and the work stoppage ended, but several months later the workers commenced a strike over a different issue than the one leading to the original order. Id.
The district court found the unions in contempt of the earlier restraining order because its plain language barred "any strike." Id. at 43-44. On appeal, the Second Circuit reversed the contempt finding. Id. at 51.
The court concluded that "despite the broad language" of the order, the order clearly "was meant to apply and should only be applied to the dispute occurring at the time of its issuance." Id. at 46.
Additionally, the court noted that "even if we considered the restraining order's scope to be a closer issue, several policy considerations e.g., the clarity requirements of Rule 65(d) counsel us to resolve all ambiguities in favor of the unions." Id. at 48.