This study provides a feminist analysis of protective labor legislation in the Supreme Court case of UAW v. Johnson Controls, Inc. History of protection rhetoric and precedented cases leading up to UAW are provided. Using a feminist analysis, this study argues that the victory for women's labor rights in UAW is short lived, and the cycle of protection rhetoric continues with new pro-business agendas replacing traditional justifications for "protecting" women in the work place. The implications of this and other findings are discussed.