Ruling creates circuit split that could reshape how employers respond to union complaints
Federal court blocks Amazon from halting labor board proceedings, closing off a strategy employers hoped would stop union complaints.
The Ninth Circuit Court of Appeals delivered the decision on December 29, 2025 in Amazon.com Services, LLC v. National Labor Relations Board, affirming that companies facing unfair labor practice charges must work through the National Labor Relations Board's administrative process even when challenging the agency's constitutional authority.
The case centers on Amazon's conflict with the Teamsters union over delivery drivers who worked for Battle Tested Strategies (BTS), a contractor Amazon terminated in April 2023. Shortly after Amazon canceled the contract, BTS recognized the Teamsters as the bargaining representative for its drivers and signed a union agreement.
The Teamsters claimed Amazon and BTS were joint employers, meaning Amazon had an obligation to bargain with the union. Amazon refused and ended the BTS relationship as planned.
That refusal triggered unfair labor practice charges with the NLRB. The union alleged Amazon threatened workers to discourage organizing, punished those who joined the union, and illegally refused to recognize the Teamsters as the drivers' representative.
Instead of defending itself through the labor board's proceedings, Amazon took a different route. The company sued the NLRB in federal court, arguing the restrictions on firing board members and administrative law judges violate the Constitution. Amazon asked a judge to halt the labor board case while courts sorted out these constitutional questions.
The Teamsters intervened in the lawsuit to protect the drivers' interests and oppose Amazon's attempt to stop the proceedings.
A district court judge rejected Amazon's request, finding the court lacked authority under a Depression-era law called the Norris-LaGuardia Act. That statute prevents federal judges from issuing injunctions in cases involving labor disputes.
Amazon appealed, arguing its constitutional challenge had nothing to do with a labor dispute. The company pointed to a recent Fifth Circuit ruling in a similar case involving SpaceX, which allowed that company's constitutional challenge to proceed.
The Ninth Circuit disagreed. Judge Danielle Forrest wrote that the law makes a distinction between the case itself and the underlying labor dispute. While the labor dispute must involve employment terms or union representation, the court case only needs to involve or grow out of that dispute.
Here, both Amazon and the Teamsters are entangled in the issues at stake. Amazon's constitutional arguments concern the agency's adjudication of the unfair labor practice claims the Teamsters initiated. The underlying dispute clearly involves employment and union representation for the delivery drivers.
The court noted that letting Amazon stop the proceedings would undercut union activity, exactly what the Norris-LaGuardia Act was designed to prevent. When the Teamsters filed their complaint with the labor board, they used the only avenue Congress gave them to pursue their claims. Blocking that process would deny them the protections labor law provides.
The panel rejected Amazon's argument that constitutional claims somehow fall outside the law's reach. Courts have previously turned down similar reasoning, the judges noted.
Amazon had urged the court to apply a different legal framework called the Thunder Basin factors, but the judges said that test applies when figuring out whether Congress implicitly stripped courts of jurisdiction. The Norris-LaGuardia Act explicitly bars injunctions in labor disputes. The statute's plain language answers the question.
The ruling creates a split with the Fifth Circuit's SpaceX decision, raising the possibility the Supreme Court could step in to resolve the conflict between the two appeals courts.
For human resources teams, the decision means constitutional challenges cannot serve as an escape hatch from labor board proceedings. Companies facing unfair labor practice charges will need to defend themselves through the NLRB's administrative system.
The case also highlights tensions around joint employer relationships, an issue that has gained urgency as more companies rely on contractors and delivery service partners. Amazon's use of this business model has drawn scrutiny from unions and labor regulators.
