Learn about the case — historical background and documents
Legal Questions Before the Courts
Did the U.S. Circuit Court for the Northern District of Illinois have authority to issue an injunction against Eugene V. Debs and the officers of the American Railway Union?
Yes, said the U.S. Supreme Court in its decision written by Justice David J. Brewer.
On July 2, 1894, Judges William A. Woods and Peter S. Grosscup, sitting in the U.S. Circuit Court for the Northern District of Illinois, concluded that irreparable harm would be done to the railroads, interstate commerce, and mail delivery if the boycott of Pullman cars continued. The judges issued an injunction ordering Debs, American Railway Union officers, and unnamed others to cease any action that might interfere with the movement of railroads operating through Chicago.
Injunctions are orders directing somebody to do or not to do something. In British and United States courts, injunctions were generally limited to cases in which the person requesting the injunction could demonstrate that irreparable harm to private property would result without the court order, that no remedy was available based on law, and that criminal prosecution would not prevent the injury to the property.
On December 14, 1894, Judge Woods, in a decision affirming the contempt citation against the union officers for violating the injunction, justified the injunction as a proper method of protecting the government’s property in the mails and cited other cases in which injunctions were used to prevent a public nuisance. Woods, as he had in the original injunction, also cited the Sherman Anti-Trust Act, which authorized the use of injunctions to prevent any obstruction of interstate commerce. The original conspiracy against the Pullman cars had become a conspiracy against “transportation and travel.”
The Supreme Court asserted a much broader authority for the injunction based on the government’s obligation to protect the general welfare of the nation. The Court agreed that the government’s property interest in the mails was sufficient to justify the injunction, but the unanimous justices also asserted the courts’ independent authority to rely on injunctions to prevent irreparable damage to public interests as well as private property.
Did the Sherman Anti-Trust Act of 1890 apply to labor unions as well as trusts and monopolies?
Yes, said the U.S. Circuit Court for the Northern District of Illinois.
The “Act to protect trade and commerce against unlawful restraints and monopolies” of July 2, 1890, better known as the Sherman Anti-Trust Act, granted the federal courts authority to issue restraining orders against combinations or conspiracies that restricted interstate trade. Although the supporters of the act wanted to limit the power of large corporate monopolies, by 1893 some federal courts accepted the act as authorization to restrain labor unions as well.
The U.S. attorney in Chicago cited the Sherman Anti-Trust Act in his request for an injunction against the American Railway Union, and the injunction issued by the circuit court relied in part on the authority of the act. Attorneys for Debs argued that the extension of the Sherman Act’s provisions to labor unions was an unconstitutional attempt to punish in a court of equity; they argued that these actions should only be subject to criminal prosecution decided by a jury, and there was no access to a jury in a court of equity. In Judge William A. Woods’ decision on the contempt citation, he concluded that the Sherman Act’s language regarding a “combination in the form of trust or otherwise” was meant to extend to any combination, including labor unions, or the word “otherwise” would not have been inserted by Congress.
In the Supreme Court, Justice David Brewer declined to address the authority granted by the Sherman Anti-Trust Act, but he insisted this should not be interpreted as a disagreement with the circuit court. The Supreme Court, Brewer added, thought it more important to focus on the “broader ground” for establishing the courts’ jurisdiction to issue injunctions against labor actions. In 1908, the Supreme Court, in Loewe v. Lawlor (the Danbury Hatters’ Case), decided that the Sherman Anti-Trust Act applied to all combinations in restraint of trade, including those presented by labor unions.
Did Eugene V. Debs and the other officers of the American Railway Union violate the injunction?
Yes, said the U.S. Circuit Court for the Northern District of Illinois.
On July 17, 1894, attorneys for the railroads and the federal government presented the U.S. circuit court with motions asserting that Debs and other union officers had failed to comply with the injunction and that they should be held in contempt of the court. The attorneys presented copies of telegrams from Debs to union members urging them to continue their strike and boycott. The comparison of telegrams from before and after the date of the injunction, the government attorneys insisted, proved that the union officers had not changed or modified their actions in support of the strike.
Judge William H. Seaman, in the U.S. circuit court, ruled that the evidence demonstrated contempt, and he order the arrest and imprisonment of Debs and the officers. Lawyers for the union officers gained court approval for further arguments on the contempt citation.
In a series of hearings presided over by Judge Woods, the lawyers for Debs argued that the strike arose from a vote of the union membership rather than the officers’ orders, that the officers had no knowledge of possible violence, that their communications with local union offices indicated no intention to obstruct interstate commerce, and that the officers had consulted with attorneys to ensure that their actions would not violate the injunction.
In his decision of December 14, 1894, Judge Woods found “voluminous” evidence of the union officers’ violation of the injunction. Woods quoted newspaper interviews with Debs in which the union president said that the injunction would have no effect on his organization of the strike. Woods also concluded that Debs had not expected his warnings against violence to be taken seriously by workers. The union officers, Woods insisted, had full control over the strike and chose not to modify their plans after the injunction or after the appearance of violence.
Did the U.S. Circuit Court for the Northern District of Illinois have the authority to hold Eugene V. Debs and other officers of the American Railway Union in contempt and to impose jail sentences?
Yes, said the U.S. Circuit Court for the Northern District of Illinois and the U.S. Supreme Court.
Attorneys for Debs and the union officers argued that the imposition of jail sentences for contempt of the injunction violated the constitutional guarantee of a trial by jury. Since the union officers had already been indicted on charges of a criminal conspiracy to obstruct commerce, the jail sentence for contempt of the injunction also represented double jeopardy.
Judge William Woods declared that the Constitution granted the federal courts equity jurisdiction and that the power to punish for contempt of an equity order was an intrinsic part of that constitutional authority. Woods also asserted that the same act could constitute contempt and a crime and that an individual could be punished for both as long as the proceedings took place in the proper courts.
Justice David Brewer in the Supreme Court was even more emphatic that the authority of a court to issue an order carries with it the authority to punish for disobedience of that order and that the same act could result in both a civil order and a criminal prosecution. Brewer concluded that the jail sentence was not an “invasion of the constitutional right of trial by jury.”
Were Eugene V. Debs and other officers of the American Railway Union guilty of criminal conspiracy to obstruct interstate commerce?
No decision was reached in the U.S. District Court for the Northern District of Illinois because the judge dismissed the jury, and the U.S. attorney chose not to retry the case.
Debs and his fellow union officers were indicted in the U.S. District Court for the Northern District of Illinois on charges of conspiracy to obstruct interstate commerce and to interrupt the delivery of the mails. In his instructions to the grand jury, Judge Peter Grosscup said that any combination of individuals to intimidate workers into striking would constitute a criminal conspiracy. Before the jury was dismissed, the U.S. attorney argued that the results of the strike, including the violence and the separation of Pullman cars from mail trains, were sufficient evidence of conspiracy. Debs testified that the activities of the union officers were all well within the recognized rights of striking workers.
Before the indictment of Debs and the others, special U.S. Attorney Edwin Walker wrote to the attorney general that “the results of a trial under the indictment will be of little importance”; the indictments alone would have the “restraining effect upon Debs and his followers.”
Related Cases
The use of injunctions against labor actions
The federal courts first issued injunctions against labor strikes during the railroad strikes of 1877, when some of the struck railroads were in bankruptcy and thus under the protective receivership of the federal courts. During the 1880s, federal courts directed injunction orders against strikers from other railroad companies in receivership. In 1888, federal courts relied on the authority of the recently enacted Interstate Commerce Act to issue injunctions against strikers at railroads that were not in bankruptcy. In 1893, William Howard Taft, as a circuit judge sitting in the Northern District of Ohio, affirmed that the Interstate Commerce Act granted the courts authority to issue injunctions against strikers who interfered with the interstate operation of railroads, and he narrowed the right to organize sympathy strikes or boycotts. In another case of 1893, the U.S. Circuit Court for the Eastern District of Louisiana became the first federal court to cite the Sherman Anti-Trust Act as authority to issue an injunction against strikers. The Sherman Act became the preferred authority to use against labor strikes involving interstate commerce.
Loewe v. Lawlor—The Sherman Anti-Trust Act applied to unions
In Loewe v. Lawlor, better known as the Danbury Hatters’ Case, the Supreme Court in 1908 decided that labor unions as well as corporate trusts were subject to the Sherman Anti-Trust Act’s prohibition on combinations or conspiracies that restrained trade.
Members of the United Hatters of North America organized a boycott of hat manufacturers that had not unionized their shops. The much larger American Federation of Labor joined in support of the boycott. A Danbury, Connecticut, hat manufacturer, Dietrich Loewe, supported by the American Anti-Boycott Association, brought a suit in the U.S. Circuit Court for Connecticut on charges that the boycott presented a combination in restraint of interstate commerce, in violation of the Sherman Anti-Trust Act of 1890. When the judge in the U.S. Circuit Court for the District of Connecticut agreed with the union attorneys that the boycott did not constitute a combination under the terms of the Sherman Anti-Trust Act, attorneys for the hat manufacturers appealed to the U.S. court of appeals, which asked for instruction from the Supreme Court.
Chief Justice Melville Fuller, who wrote the opinion for a unanimous Supreme Court, said that the Sherman Anti-Trust Act made “no distinction between classes,” and the act applied to any restraint of interstate commerce, even if the individuals named in the suit were not themselves involved in interstate commerce. Examining the congressional record, Fuller noted that the Congress had considered an exemption for farmers and laborers and decided to omit any such exception.
Justice David Brewer’s decision for In re Debs offered no opinion on the application of the Sherman Act to labor unions, but it pointedly stated that no one should conclude that the Supreme Court differed with the U.S. Circuit Court for the Northern District of Illinois, which had ruled that the act applied to labor organizations.
The Debs Case: Labor, Capital, and the Federal Courts of the 1890s