Radio & Television Broadcast Technicians Local Union 1264 v. Broadcast Serv. of Mobile, Inc., 380 U.S. 255 (1965). · Go Syfert
Radio & Television Broadcast Technicians Local Union 1264 v. Broadcast Serv. of Mobile, Inc., 380 U.S. 255 (1965). Cases Citing This Book View Copy Cite
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Related entities constitute a single employer for jurisdictional purposes under the National Labor Relations Act when they comprise an integrated enterprise.

A union challenged a state court's jurisdiction over a suit to restrain picketing, arguing the employer was part of an integrated enterprise with gross receipts exceeding the National Labor Relations Board's jurisdictional minimum. The court must determine if the employer is a single entity under Board standards. To determine if multiple business entities constitute a single employer, the Board considers the interrelation of operations, common management, centralized control of labor relations, and common ownership. Because the record showed these factors were present in the enterprise, the federal enactment requires that state jurisdiction must yield to the Board's jurisdiction.

1,076 citation events (299 in the last 25 years) across 75 distinct courts.
Treatment trajectory · 1965 → 2026 · click a year to view as-of
1965 1995 2026
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Citations from separate opinions of courts that could overrule this case. This is a warning signal, not a treatment change. The flag color above is unaffected.
Concurrence Agency for Int'l Dev. v. All. for Open Soc'y Int'l, Inc., 591 U.S. 430 (2020)
“Radio & Television Technicians v. Broadcast Service of Mobile, Inc. , 380 U.S. 255 , 256, 85 S.Ct. 876 , 13 L.Ed.2d 789 (1965) ( per curiam ).”
Cited for
At page 256 Determining single employer status for jurisdiction62 citing cases“interrelation of operations, common management, centralized control of labor relations and common ownership.”16 citing courts quote it · also cited as 85 S. Ct. at 877; 13 L. Ed. 2d at 790 · 61 listed here
  • Innes, No. 1:22-cv-00641 (N.D.N.Y. Feb. 23, 2026).
    (Solid Waste Servs., Inc.)
  • Cardinale v. S. Homes of Polk Cnty., Inc., 310 F. App'x 311 (11th Cir. 2009).unpublished 5 cites
    (The controlling criteria, set out and elaborated in Board decisions, are interrelation of operations, common management, centralized control of labor relations and common ownership.)
  • Florence, No. 1:25-cv-07082 (S.D.N.Y. Aug. 5, 2026).
    Serv. of Mobile, Inc., 380 U.S. 255, 256 (1965); Shukla v. Viacom Inc., 2019 WL 1932568 , at *8 (S.D.N.Y.
  • Killion v. Patel, No. 1:24-cv-00337 (S.D. Ind. July 10, 2025). 4 cites
    The single-employer doctrine, also referred to as the "integrated enterprise" doctrine, is a "judicially created" doctrine that "originated in the area of labor relations." Rogers v. Sugar Tree Prods., Inc., 7 F.3d 577, 582 (7th Cir. 1993)…
  • Steinberg v. Cushman & Wakefield, Inc., No. 1:24-cv-06470 (S.D.N.Y. Mar. 11, 2025).
    Broadcast Technicians Local Union v. Broadcast Serv. of Mobile, Inc., 380 U.S. 255, 256 (1965)).
  • Gesualdi v. Advanced Ready Mix Corp., 768 F. Supp. 3d 451 (E.D.N.Y. 2025).published
    Union 1264 v. Broadcast Serv. of Mobile, Inc., 380 U.S. 255, 256 (1965) (per curiam)).
  • United States v. Pathway of Baldwin Cnty., LLC, No. 1:17-cv-00355 (S.D. Ala. Oct. 10, 2024).
    Serv. of Mobile, Inc., 380 U.S. 255, 256 (1965).
  • Natale v. Allied Aviation Servs., Inc, No. 1:23-cv-07260 (S.D.N.Y. Aug. 13, 2024).
    Union 1264 v. Broadcast Serv. of Mobile, Inc., 380 U.S. 255, 256 (1965) (per curiam).
  • Chamber of Com. of the United States of Am., No. 6:23-cv-00553 (E.D. Tex. Mar. 18, 2024).
    Serv. of Mobile, Inc., 380 U.S. 255, 256 (1965).
  • Womochil v. Averette Co. Inc, The, No. 2:22-cv-00321 (N.D. Ala. Feb. 21, 2024).
    Union 1264 v. Broadcast Serv. of Mobile, Inc., 380 U.S. 255, 256 (1965)3.
Show 51 more citing cases
At page 257 142 N. L. R. B. 615. The record made below is more than adequate to show that all of these factors are present in regard to the Holt enterprise * and that this…1 citing caseopening of page *257 (no citing court says what it cites this page for)
  • Telano v. Evans Oil Co L L C, No. 3:18-cv-01460 (W.D. La. Dec. 26, 2019).
    In considering whether an entity related to an employer may be liable under Title VII as an integrated or single employer, the Fifth Circuit follows the four-factor test adopted by the United States Supreme Court in the context of a labor…
Other citing cases4 with no pin cite or quoted language on record
Retrieving the full opinion text from the archive…
RADIO & TELEVISION BROADCAST TECHNICIANS LOCAL UNION 1264, INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS, AFL-CIO, Et Al.
v.
BROADCAST SERVICE OF MOBILE, INC.
61.
Supreme Court of the United States.
Mar 15, 1965.
Published opinion
380 U.S. 255
1965 U.S. LEXIS 2311
J. R. Goldthwaite, Jr., argued the cause and filed a brief for petitioners., Willis C. Darby, Jr., argued the cause for respondent. With him on the brief was George E. Stone, Jr., Solicitor General Cox, Arnold Ordman, Dominick L. Manoli and Norton J. Come filed a brief for the United States, as amicus curiae, urging reversal.
Per Curiam.
Cited by 340 opinions  |  Published
1 passages pin-cited by 1 case
Pinpoint authority: bottom 84%
Citer courts: Eleventh Circuit (3)
Per Curiam.

The union, Radio and Television Broadcast Technicians, challenged the Alabama Circuit Court's jurisdiction over a suit by Broadcast Service of Mobile, the corporate name of Radio Station WSIM, to restrain peaceful picketing by the union and its solicitation of advertisers aimed at persuading them to cease doing business with the station. It contended that although the annual gross receipts of WSIM are below the National Labor[*256] Relations Board’s jurisdictional minimum of $100,000 per year for radio stations, WSIM is an integral part of a group of radio stations owned and operated by Charles W. Holt and the Holt Broadcasting Service and that the annual receipts of the common enterprise are in excess of $100,000, which is determinative under the Board’s standards. Stating that every court has judicial power to determine its jurisdiction and that the union failed to allege "that the appellant’s [WSIM’s] gross business exceeded $100,000 per annum,” the Alabama Supreme Court held that the state courts had jurisdiction over WSIM’s complaint. We granted certiorari. 379 U. S. 812. The judgment below must be reversed.

Although a state court may assume jurisdiction over labor disputes over which the National Labor Relations Board has, but declines to assert, jurisdiction, 29 U. S. C. §§ 164 (c)(1) and (2) (1958 ed., Supp. V), there must be a proper determination of whether the case is actually one of those which the Board will decline to hear. Hattiesburg Building Trades Council v. Broome, 377 U. S. 126. The Board will assert jurisdiction over an employer operating a radio station if his gross receipts equal or exceed $100,000 per year, Raritan Valley Broadcasting Co., 122 N. L. R. B. 90, and in determining the relevant employer, the Board considers several nominally separate business entities to be a single employer where they comprise an integrated enterprise, N. L. R. B. twenty-first Ann. Rep. 14-15 (1956). The controlling criteria, set out and elaborated in Board decisions, are interrelation of operations, common management, centralized control of labor relations and common ownership. Sakrete of Northern California, Inc., 137 N. L. R. B. 1220, aff’d 332 F. 2d 902 (C. A. 9th Cir.), cert. denied, 379 U. S. 961; Family Laundry, Inc., 121 N. L. R. B. 1619; Canton, Carp’s, Inc., 125 N. L. R. B. 483; V. I. P. Radio, Inc., 128 N. L. R. B. 113; Perfect T. V., Inc., 134 N. L. R. B. 575; Overton Markets, Inc., [*257] 142 N. L. R. B. 615. The record made below is more than adequate to show that all of these factors are present in regard to the Holt enterprise * and that this is not a case which the Board has announced it would decline to hear. Since the conduct set out in the complaint is regulated by the Labor Management Relations Act, 1947, 29 U. S. C. § 141 et seq. (1958 ed.), “due regard for the federal enactment requires that state jurisdiction must yield.” San Diego Building Trades v. Garmon, 359 U. S. 236, 244; Construction & General Laborers’ Union v. Curry, 371 U. S. 542.

Reversed.

*

The United States, as amicus curiae, confirms the view that the Board’s standards for determining a single employer enterprise were fully satisfied by the structure and operation of the Holt stations.