Actions

Debs, In re

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Significance: The Supreme Court upheld a federal injunction against a labor union in order to protect the U.S. mails and to preserve the orderly movement of interstate commerce. Also, the Court implicitly permitted lower courts to apply the Sherman Antitrust Act (1890) to labor unions.


During the famous Pullman strike in Chicago, members of the American Railway Union throughout the nation refused to handle trains carrying Pullman cars. When this resulted in firings, the union declared new strikes. President Grover Cleveland's administration sought and obtained a federal injunction against the strikers. The circuit court justified the injunction under the Sherman Antitrust Act of 1890 and the authority of the federal government to deliver the mails. With the spread of violence, Cleveland sent federal troops to Chicago to preserve order. When Eugene Debs, president of the union, refused to honor the injunction, he was held in contempt and given a sentence of six months in jail. He appealed to the Supreme Court on a writ of habeas corpus. Speaking for a unanimous Court, Justice David J. Brewer upheld the injunction and the contempt citation of Debs. Brewer reasoned that the national government possessed a broad constitutional mandate to remove obstacles to interstate commerce and movement of the mails and that it might choose to use either military power or the equity jurisdiction of the federal courts. By maintaining silence about the lower court's reliance on the Sherman Antitrust Act, Brewer's opinion left the door open for antitrust injunctions against union activities in interstate commerce. In Loewe v. Lawlor (1906), the Court explicitly ruled that the Sherman Antitrust Act applied to combinations of workers. The Clayton Act of 1914 exempted labor unions from antitrust injunctions, but the use of injunctions to stop strikes continued until the New Deal period.