Loewe v. Lawlor

In a unanimous ruling, all nine justices found that the secondary boycott organized by the United Hatters was illegal under the Sherman Anti-Trust Act, which, said the Court "prohibits any combination which essentially obstructs the free flow of commerce between the States . . . " Moreover, the Court added:

A combination may be in restraint of interstate trade and within the meaning of the Anti-Trust Act although the persons exercising the restraint may not themselves be engaged in interstate trade . . . The Anti-Trust Act of July 2, 1890 makes no distinctions between classes. Organizations of farmers and laborers were not exempted from its operation . . .

Therefore, said the Court, Martin Lawlor did indeed owe $80,000 in damages to D. E. Loewe.

Unions across the country were furious with the decision in Loewe v. Lawlor. They were also scared. If manufacturers could sue them for such enormous sums every time they tried to organize, they would soon be unable to take any action at all.

Since the judicial system seemed so unsympathetic to labor, unions tried the legislative route. They helped pass the Clayton Antitrust Act of 1914, which specifically exempted labor unions from suits brought under the antitrust laws. Real legal relief for labor, however, was not to come until the 1930s, when heightened labor militancy and an increased number of strikes created a whole new set of laws recognizing workers' right to organize.