Dorchy v. Kansas

Background

A coal company, its miners’ union, and two union officers are at the center of this case. The union’s president and vice‑president called a strike after the union demanded payment for a worker’s disputed $180 claim. There was no wage or safety dispute with the employer, and the men were told not to return until the claim was paid. The vice‑president was prosecuted under a Kansas law that makes it a felony for a union officer to use his position to induce others to quit work to hinder mining operations.

Reasoning

The Court focused on whether applying the Kansas statute to these facts violated the Fourteenth Amendment’s protection of liberty. The strike here aimed to coerce the company into paying a private, disputed debt, not to resolve a workplace dispute about wages or conditions. The Court explained a legislature may criminalize coercive conduct used to interfere with a business, and that the Constitution does not confer an absolute right to strike in all circumstances. Because this strike was called to compel payment of a private claim, the law could validly punish a union officer who used his office to induce the work stoppage. The Court therefore affirmed the conviction.

Real world impact

The decision means state law can criminally punish union leaders who order strikes intended to coerce employers into paying private claims. It does not decide whether all strikes may be banned; rather, it permits punishment when the strike’s purpose is coercive and outside ordinary labor disputes.