The Sixth Circuit Court of Appeals recently extended the limits within which an employer might lock out his employees. While the Supreme Court has allowed a lockout initiated after an impasse in negotiations between the employer and the union, the Sixth Circuit held that a lockout prior to an impasse for the purpose of supporting the employer's bargaining position was not an unfair labor practice.
Labor Law: Bargaining Lockout Held Lawful Absent Interference With Protected Rights or a Proscribed Purpose,
1966 Duke Law Journal
Available at: http://scholarship.law.duke.edu/dlj/vol15/iss1/13