New York Court Denies Nurses Union's Request for Emergency Payment Order

Ruling finds union failed to show court jurisdiction under Norris-LaGuardia Act

Published on Feb. 18, 2026

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A New York federal district court denied the New York State Nurses Association's renewed motion for a temporary restraining order against the Brooklyn Hospital Center. The court found the union failed to establish the court's jurisdiction to order immediate payment of allegedly overdue benefit fund contributions while arbitration was pending, as the union did not demonstrate the absence of such relief would threaten the integrity of the arbitration process itself, which is required for a 'reverse Boys Markets' injunction to preserve the status quo.

Why it matters

This ruling highlights the challenges unions face in seeking emergency court orders against employers during labor disputes, as courts have limited jurisdiction to intervene in ongoing arbitration processes under the Norris-LaGuardia Act.

The details

The New York State Nurses Association (NYSNA) had sought a temporary restraining order against the Brooklyn Hospital Center to compel immediate payment of allegedly overdue benefit fund contributions. However, the federal district court found that NYSNA failed to demonstrate the court had jurisdiction to grant such relief under the Norris-LaGuardia Act, which limits the ability of courts to issue injunctions in labor disputes.

  • The ruling was issued on February 17, 2026.

The players

New York State Nurses Association

A labor union representing nurses in New York.

Brooklyn Hospital Center

A hospital located in Brooklyn, New York.

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The takeaway

The court's decision underscores the legal constraints on unions' ability to obtain immediate court-ordered relief against employers during labor disputes, even when benefit fund contributions are allegedly overdue. This case illustrates the delicate balance courts must strike between respecting the arbitration process and providing timely intervention to preserve the status quo.