Truax v. Corrigan

1921-12-19

Headline: Arizona rule limiting injunctions in labor disputes is struck down, Court reverses state decision and allows courts to block coercive picketing and boycotts that destroy businesses, protecting owners’ property rights.

Holding: The Court held Arizona’s statute barring injunctions in labor disputes cannot be applied to make libelous, coercive picketing and boycotts remediless, and reversed the state court, restoring plaintiffs’ ability to seek injunctions.

Real World Impact:

Allows courts to enjoin coercive picketing and boycotts that destroy businesses.
Protects business owners’ right to seek injunctions against libelous labor campaigns.
Leaves peaceful, noncoercive persuasion lawful for workers and unions.

Topics: labor disputes, picketing and boycotts, property rights, injunctions

Summary

Background

The plaintiffs are the owners of the English Kitchen, a Bisbee, Arizona restaurant. In 1916 a labor dispute led the cooks, waiters and their union to strike and organize picketing, loud denunciations, and handbills accusing the owners and employees. The complaint alleged continuous patrolling within five feet of the entrance, loud appeals, libelous handbills and threats toward customers. The owners said the campaign reduced annual receipts from about $55,000 to $12,000 and threatened destruction of the business, so they sought an injunction, claiming Paragraph 1464 of the Arizona Code barred equitable relief.

Reasoning

The Supreme Court, through Chief Justice Taft, treated the pleaded facts as true and held that a going business and free access to its premises are property. The Court found the campaign alleged was not mere persuasion but a conspiracy using libel, obstruction and moral coercion that prevented customers from entering. It held the Arizona statute, as construed by the state court, effectively made such wrongful conduct remediless and thus denied due process and equal protection. The Court reversed, remanded, and ordered the defendants to answer so an injunction could issue if proof supports the complaint.

Real world impact

This ruling means state law cannot be read to give blanket immunity to coercive picketing and boycotts that destroy a business; harmed proprietors can seek injunctions when proof shows libel, obstruction, or moral coercion. Peaceful, noncoercive persuasion remains lawful. The case was sent back for further proceedings.

Dissents or concurrances

Three Justices dissented, saying states may limit equity relief in labor disputes, that the legislature can experiment with remedies, and that courts should not use the Fourteenth Amendment to block state policy changes or to second-guess social experiments about injunctions.