The Eighth Circuit has handed the owners an encouraging win by granting a stay of the injunction of the owner's lockout. In so doing the court does a pretty good job of explaining how the Norris-LaGuardia Act prohibits injunctions of labor disputes. A labor dispute can occur even in the absence of a certified union, thus the player's decertification, in the court's view, did not make the Norris-LaGuardia Act's prohibitions on injunctions inapplicable.

In a somewhat unusual move, the United States Court of Appeals for the Eighth Circuit has issued a temporary administrative stay of Judge Nelson's order enjoining the NFL owner's lockout. The stay is a procedural device to allow the court enough time to do a preliminary review a matter. Normally it is used for emergency situations like death row appeals. Many commentators expect a ruling next week.