Mercy-Memorial Hospital Corp. v. Hospital Employees' Division of Local 79

How later courts describe this case

• holding that violations of § 186 of the Taft-Hartley Act are intended to supplement the NLRA, and not be preempted by it
• sealing the record of in camera discussions with FBI agent about attempts to bribe jury members
• mere fact that “attorney worked on a prospectus does not make him a ‘seller’ under the securities laws”
• “our analysis of relatedness and continuity has shifted from the enterprise element to the pattern element.”
• “The Garmon and other doctrines are not designed to preempt other independent rights created by Congress,.... ”
• “Congress’s goal in fashioning its definition of ‘pattern of racketeering activity’ was to exclude from the reach of RICO criminal acts that were merely ‘isolated’ or ‘sporadic’____”
• “Even if we were not convinced that the district court correctly found an absence of jury prejudice here, we would not permit the perpetrator of jury tampering, in a civil proceeding, to reap the rewards of his misdeed by enjoying a new trial.”
• bond underwriters’ counsel not primarily liable under Rule 10b-5 for failure to correct misleading prospectus statements where it did not sign prospectus or accompanying documents and did not prepare formal written legal opinion for benefit of bond purchasers