Truax v. Corrigan
The Supreme Court struck down an Arizona law that stopped courts from issuing injunctions against peaceful picketing and boycotts arising from labor disputes, ruling that a restaurant owner whose business was devastated by an aggressive union boycott campaign was wrongly denied the same court protection any other business owner could get.
The decision held that singling out labor disputes for this kind of special treatment violated both due process and equal protection, cementing the injunction as a tool employers could use against strikes and picketing for years until Congress later curtailed it.
“Violence could not have been more effective. It was moral coercion by illegal annoyance and obstruction and it thus was plainly a conspiracy.”
The majority explains why the union's boycott tactics amounted to an unlawful conspiracy despite lacking physical violence.
How it got here: An Arizona trial court dismissed the complaint on demurrer relying on a state law barring labor-dispute injunctions; the Arizona Supreme Court affirmed, and Truax brought the case to the U.S. Supreme Court.
The Case in Depth
What happened
William Truax and his partners ran a restaurant in Bisbee, Arizona. After a pay dispute, their cooks and waiters walked out and, with their union, launched a boycott campaign featuring picketing, banners, loud denunciations, and handbills with abusive and libelous claims about Truax and his customers. The campaign cut the restaurant's business from about $55,000 a year to $12,000, and Truax sued for an injunction.
The question before the Court
Could Arizona bar a restaurant owner from getting a court order to stop a union's boycott and picketing campaign, even though other business owners in the same situation could get one?
The Court's answer
No — the Court ruled that Arizona could not shield this kind of ex-employee boycott campaign from injunctions while allowing injunctions against identical conduct by anyone else, such as a competing business. The Court treated the restaurant's business and its customers' free access to it as property rights, and found that the union's libelous handbills, loud denunciations, and continuous picketing amounted to an unlawful conspiracy causing real, serious harm — not peaceful, protected persuasion.
Because Arizona's law left the restaurant owner with no meaningful remedy for this unlawful conduct simply because the wrongdoers were former employees, the Court held the law violated both due process, by stripping away all real protection for a property right, and equal protection, by granting one class of tortfeasors immunity that others in the same position did not receive.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Employers gained a continued green light to seek injunctions shutting down aggressive strike tactics, while unions lost a key legislative protection meant to keep courts out of labor disputes. The ruling shaped labor relations nationwide until Congress passed the Norris-LaGuardia Act in 1932 to restrict labor injunctions again.
What changes now
The case was sent back to the Arizona courts for further proceedings consistent with the Supreme Court's ruling, meaning the restaurant owner could now pursue his request for an injunction against the boycott. As a final merits decision, this ruling stood as controlling precedent on labor injunctions until Congress passed the Norris-LaGuardia Act in 1932, which broadly restricted the power of federal courts to issue such injunctions in labor disputes.
What this does not decide
The Court did not rule that all restrictions on labor injunctions are unconstitutional, nor that ordinary peaceful picketing or boycotts are always unlawful. It emphasized this was not a routine peaceful secondary boycott case, and that its equal-protection holding turned on Arizona's law completely exempting one class of wrongdoers from a remedy available against everyone else.
Concurrences and dissents
Dissent — Justice Holmes
“By calling a business "property" you make it seem like land, and lead up to the conclusion that a statute cannot substantially cut down the advantages of ownership existing before the statute was passed.”Holmes criticizes the majority's reasoning for treating a business like a fixed piece of property.
Justice Holmes argued that calling a business 'property' creates a false sense that it cannot be altered by statute, when in truth a business is just a course of conduct subject to legislative change. He saw no constitutional problem with Arizona choosing to deny the extraordinary remedy of injunction in labor cases, since legislatures may address evils incrementally, and warned against using the Fourteenth Amendment to block state social experiments.
Dissent — Justice Pitney
Justice Pitney argued that no one has a vested right in a particular legal remedy, so Arizona was free to restrict injunctions in labor disputes as an exercise of its police power without violating due process. He also found no equal protection violation because the law applied evenly to everyone involved in employer-employee disputes, and the plaintiffs could not complain about treatment of unrelated third parties like competing businesses.
Dissent — Justice Brandeis
Justice Brandeis, drawing on an extensive comparative history of labor law in England, its dominions, and the United States, argued that rules governing labor disputes are properly subject to ongoing legislative experimentation and that states may curtail equity remedies like injunctions as a legitimate exercise of the police power. He concluded Arizona's law was neither arbitrary under due process nor discriminatory under equal protection, since restricting an extraordinary remedy in the public interest does not deny fundamental rights.
How the Court got there
The legal reasoning, step by step
- The Court treated the ability to run a business, and to have customers freely reach it, as a property right that the law protects against intentional injury caused by a conspiracy — a scheme by multiple people to inflict harm through unlawful means.
- Reviewing the facts admitted by the demurrer (a procedural motion arguing that even if the facts alleged are true, there's no valid legal claim), the Court found the union's conduct went beyond peaceful appeals: constant picketing right at the entrance, loud denunciations all day, and handbills with libelous, abusive claims about the owner, his employees, and his customers.
- Because these methods amounted to moral coercion through illegal annoyance, libel, and obstruction rather than simple persuasion, the Court concluded the boycott campaign used unlawful means and was therefore an unlawful conspiracy, not a protected labor dispute tactic.
- Applying due process, the Court reasoned that a law making such unlawful conduct effectively immune from any court relief strips the owner of all real protection for his property, which no legislature may do consistent with fundamental fairness.
- Applying the equal protection guarantee — the requirement that people in like circumstances be treated alike under the law — the Court found that Arizona's law let ex-employees escape injunctions for this exact wrongdoing while any other wrongdoer, such as a business competitor, would still face one, an unjustified and arbitrary distinction.
- The Court distinguished this case from prior rulings upholding special employer-employee legislation (like workers' compensation laws), reasoning those cases involved adjusting the rules of an ongoing employment relationship, not stripping a former employer of protection against a stranger's tort after the relationship had ended.
Doctrinal impact
Cases affected by this decision
Distinguishes Connolly v. Union Sewer Pipe Co. (184 U.S. 540)
The Court distinguished this equal-protection precedent, saying unlike there, Arizona's older general injunction law could survive even if the newer exception was struck down.