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Allen Bradley Co. v. Local 3, International Brotherhood of Electrical Workers
United States Supreme Court
325 U.S. 797 (1945)
Local No. 3 of the International Brotherhood of Electrical Workers (the union) (defendant) had jurisdiction over the metropolitan area of New York City. Some union members worked for local manufacturers that produced electrical equipment, and some union members worked for contractors who installed electrical equipment. Over time, the union negotiated closed-shop agreements with all local electrical equipment manufacturers and contractors, utilizing traditional labor-union methods such as strikes and boycotts to obtain the agreements. Under the agreements, local equipment manufacturers could only sell their products to contractors employing union members, and contractors could only purchase equipment from local manufacturers. The result was that external manufacturers of electrical equipment (those outside the union’s area of jurisdiction) were effectively excluded from the market in New York City. The external manufacturers (plaintiffs) initiated an action against the union, alleging violations of the Sherman Antitrust Act. The district court issued an injunction against the union. The court of appeals reversed and dismissed the action. The matter came before the Supreme Court.
Rule of Law
Holding and Reasoning (Black, J.)
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