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HE question presented is whether federal law restricts state power to enjoin a strike as in violation of a collective bargaining agreement. The relevant sources of federal law are the Norris-LaGuardia Act I and section 3o i(a) of the Labor-Management Relations (Taft-Hartley) Act.2 (i) It seems clear that the Norris-LaGuardia Act does not itself apply to actions in state courts. It is doubtless true that many of the animating principles underlying the I932 statute are implicated whenever a strike is sought to be subjected to the control of equity, in state or federal court.3 Moreover, the Supreme Court has dramatically sustained the attribution of substantive import to Norris-LaGuardia, despite the act's jurisdictional language, as a legislative response to judicial interpretation of earlier statutory regulation.4 Finally, it is at least part of the story to note that the statute was cast as it was because of doubts, soon thereafter dispelled, whether Congress had power to make substantive law to govern labor disputes.5 The fact remains that the decision was made to write a statute addressed to the federal courts, that the problem there may have been thought at

State-Court Injunctions and the Federal Common Law of Labor Contracts: Beyond Norris-LaGuardia