Paine Lumber Co. v. Neal

Background

Out-of-state manufacturers who made doors, sash, and similar wood products sued officers and members of a New York carpenters’ union, some union manufacturers, and master carpenters. The manufacturers say the unions agreed not to install or work with material made by nonunion mechanics and adopted arbitration plans and by-laws that effectively block nonunion goods from being used in much of Manhattan and parts of Brooklyn, cutting the plaintiffs’ sales in those city markets. The manufacturers asked a court to stop the unions from enforcing those agreements and to declare parts of them void.

Reasoning

The core question was whether private companies could get an injunction in federal court to stop the alleged boycott and restraint on their interstate sales. The majority concluded that a private person cannot maintain the sort of injunction sought under §4 of the Sherman Act and that, even though the 1914 Clayton Act gave private parties a right to injunctions in some cases, the policy of the law did not support granting one here. The lower courts had also found no special acts directed only at these manufacturers, and the Supreme Court affirmed the dismissal of the bill.

Real world impact

As a result, these manufacturers cannot use a federal injunction to stop the unions’ refusal to work with nonunion-made material in the city, and their access to those urban markets remains reduced. The dissent argued that equity principles and the Clayton Act should allow private injunctive relief where continuing, irreparable harm to property rights is shown, but the majority declined to grant relief.

Dissents or concurrances

Three Justices dissented, arguing private parties facing direct, continuing injury from union boycotts could obtain injunctions under equitable principles and the Clayton Act; they would have reversed the dismissal.