Atkinson v. Sinclair Refining Co
In Atkinson v. Sinclair Refining Co., 370 U.S. 238 (1962), the Court relied on the intent of Congress in passing federal labor law 301 (b) to hold that individual union members may not be sued for damages where the union has breached the no-strike provision of its collective-bargaining agreement.
Section 301 (b) states in pertinent part that "any money judgment against a labor organization . . . shall be enforceable only against the organization as an entity and against its assets, and shall not be enforceable against any individual member or his assets."
Thus, in Atkinson, we noted that "in discharging the duty Congress imposed on us to formulate the federal law to govern 301 (a) suits, we are strongly guided by and do not give a niggardly reading to 301 (b)." (Ibid.)
Accordingly, the Supreme Court consulted and relied on the legislative history of 301 (b) which made it "clear that the third clause of 301 (b) was a deeply felt congressional reaction against the Danbury Hatters case . . . and an expression of legislative determination that the aftermath . . . of that decision was not to be permitted to recur." Id., at 248.