The panel affirmed the district court’s order denying Amazon.com Services, LLC’s motion for a preliminary injunction to stop administrative proceedings before the National Labor Relations Board (Board) after Amazon was charged with unfair-labor practices under the National Labor Relations Act for refusing to recognize and bargain with the Teamsters Amazon National Negotiating Committee (Teamsters), which represent a group of former Amazon delivery drivers.

Amazon argued that the Board and its administrative procedures for adjudicating labor disputes are unconstitutional and sued to enjoin the Board and its named officials from engaging in unconstitutional administrative proceedings. The district court concluded that it lacked jurisdiction to issue the requested relief under the Norris-LaGuardia Act, 29 U.S.C. § 113, which strips federal courts of power “to issue any . . . injunction in a case involving or growing out of a labor dispute.”

The panel held that the definition of “labor dispute” set forth in the Norris-LaGuardia Act, 29 U.S.C. § 113(a), imposes separate mandates for the pending case and the underlying labor dispute, both of which were satisfied here. First, the panel held that section 113(a)’s case-related requirements were satisfied. Both Amazon and the Teamsters are entangled in or implicated in the issues to be decided here because Amazon’s constitutional challenges concern the agency’s adjudication of the ULP claims that the Teamsters initiated. Second, the panel also held that the underlying Board proceeding is obviously a labor dispute. It concerns the terms of employment and the representation of the drivers, and the dispute is between employers and employees, namely, Amazon and the Teamsters. Accordingly, the panel affirmed the district court’s denial of Amazon’s motion for a preliminary injunction.

https://cdn.ca9.uscourts.gov/datastore/opinions/2025/12/29/25-886.pdf