Loewe v. Lawlor
Loewe v. Lawlor is a landmark Supreme Court case from 1908 that addressed the legal status of labor unions in relation to antitrust laws. Initiated by an employer's lawsuit against individual members of the United Hatters of America, the case arose in the context of a secondary boycott organized by the American Federation of Labor. The union argued that the Sherman Antitrust Act of 1890 was intended solely for business corporations and should not apply to labor organizations. However, the Supreme Court, led by Chief Justice Melville W. Fuller, ruled unanimously in favor of the employer, determining that the Sherman Antitrust Act encompassed all combinations that restrained trade, including labor unions. This decision significantly heightened the legal risks for unions, exposing them to injunctions and damage claims. Although the Clayton Act of 1914 later offered some protections for unions, the Danbury Hatters' decision marked a crucial moment in the evolution of labor rights in the United States. The case illustrates the ongoing tension between labor rights and antitrust regulations, an issue that continues to resonate in contemporary discussions about workers' rights and corporate power.
Loewe v. Lawlor
Date: February 3, 1908
Citation: 208 U.S. 274
Issue: Sherman Antitrust Act
Significance: In the so-called Danbury Hatters’ case, the Supreme Court held that a boycott against a manufacturer of hats, initiated in an attempt to force unionization, was an illegal restraint of trade.
Reacting to a secondary boycott sponsored by the American Federation of Labor, an employer brought suit against individual members of the United Hatters of America. The union claimed that the Sherman Antitrust Act of 1890 was designed for business corporations, not labor unions. Speaking for a unanimous Supreme Court, Chief Justice Melville W. Fuller ruled in favor of the employer. Fuller concluded that the Sherman Antitrust Act applied to all combinations in restraint of trade, and he found no evidence that Congress had intended to exempt labor unions from coverage. The Danbury Hatters’ decision greatly increased the vulnerability of labor unions to injunctions and damage suits, but the Clayton Act of 1914 provided unions with partial relief.
