Gompers v. Buck's Stove & Range Company

During the 1800s, many laborers and workers organized and formed unions to strengthen their bargaining power to negotiate for better working conditions and wages. Courts were reluctant to restrict or restrain these efforts, in consideration of First Amendment protections of freedom of speech (e.g., the right to speak out against unfair conditions) and freedom of association (e.g., the right to join with others to speak out against unfair conditions). However, courts also needed to weigh or balance conflicting individual freedoms, particularly where certain freedoms of expression might result in harm or damage to the property rights of others.

With the rise in interstate commerce, individual labor unions began to form voluntary associations with others under the umbrella organization of the American Federation of Labor (AF of L, later AFL). This enhancement of bargaining power for individual laborers was intimidating to manufacturers and producers, who formed their own professional affiliations and associations, in a reciprocal effort to maintain equal bargaining power.