On June 13, 2024, in Starbucks v. McKinney, the U.S. Supreme Court reverted to an older and more stringent four-part test to be used when the National Labor Relations Board (NLRB) seeks an injunction against an employer. The NLRB enforces the National Labor Relations Act’s (NLRA) prohibition on employers engaging in unfair labor practices. Due to the lengthy nature of NLRB proceedings, the NLRB often seeks a preliminary injunction against an employer to stop what it believes is an unfair labor practice during the pendency of the suit. This traditional four-part test makes it more difficult for the NLRB to obtain such an injunction. The NLRB must show that (1) the plaintiff is likely to succeed on the merits, (2) they are likely to suffer irreparable harm in the absence of preliminary relief, (3) that the balance of equities tips in their favor, and (4) that an injunction is in the public interest. It replaces the modern and easier two-part test that asks only whether there is reasonable cause to believe unfair labor practices have occurred, and whether injunctive relief is “just and proper.” While the 5^th Circuit, which encompasses Virginia, had already adopted the four-part test, the 6^th Circuit, which encompasses Tennessee, had employed the easier two-part test. In Tennessee, then, this employer-friendly move from the Supreme Court will change how Tennessee federal courts review the NLRB’s requests for injunctions and is likely to decrease how often the NLRB obtains an injunction against an employer.