In NLRB v. Retail Store Employees Local 1001 (Safeco), the Supreme Court held that primary product picketing at a neutral secondary retailer's place of business that can be reasonably expected to threaten the neutral party with ruin or substantial loss is prohibited by section 8(b)(4)(i,ii)(B) of the National Labor Relations Act (NLRA).
Safeco Title Insurance Company (Safeco) is a California corporation engaged in the operation of a title insurance company in Seattle, Washington. Safeco employees were represented in the collective bargaining process by the Retail Store Employees Union Local 1001, Retail Clerks International Association, AFL-CIO. Negotiations between Safeco and the union reached an impasse in November of 1974, and on November 18, 1974 the union commenced a strike against Safeco's Seattle offices. A few months later, the strikers began picketing five independently operated Washington title insurance companies that issued policies underwritten exclusively by Safeco. The five independent title companies derived ninety to ninety-five percent of their total income from the issuance of the Safeco title insurance policies. Safeco owned varying stock interests in each of the five Washington companies and also had one of its own officers serving as an officer and member of the board of directors of each land title company. The Land Title Company of Pierce County and Safeco filed charges with the National Labor Relations Board (Board) contending that the union's picketing of the title companies violated section 8(b)(4)(ii)(B) of the Act.
Kinman, Joseph F. Jr.
"Safeco and Secondary Product Picketing,"
Mercer Law Review: Vol. 32:
3, Article 10.
Available at: https://digitalcommons.law.mercer.edu/jour_mlr/vol32/iss3/10