Duplex Printing Press Co. v. Deering

Duplex Printing Press Co. (Duplex) (plaintiff) manufactured newspaper presses at a factory in Michigan and sold its products to customers around the nation. Once a Duplex printing press was sold, it would be installed by the customer’s employees, but the complex installation process was overseen by Duplex’s machinists. Duplex employed both machinists who belonged to a local union (the union) (defendant) and nonunion machinists, operating what was known as an open shop. Duplex would not agree to the union’s demand for a closed shop or union terms on wages and hours. In August 1913, the union initiated a strike at Duplex’s factory in Michigan. The strike failed to materially affect Duplex’s operations, and printing presses continued to be installed at customer sites. Thereafter, the union implemented a program of boycotting Duplex’s product in and around New York City, including trying to stop shipments, threatening Duplex’s customers with strikes, and exerting pressure on customers to stop purchasing and installing Duplex printing presses. Duplex filed suit against the union in federal district court, seeking an injunction against the union’s boycott. The district court denied Duplex’s request, and Duplex appealed. The court of appeals concluded that the district court did not have the power to issue an injunction under the Clayton Act. The Supreme Court granted review.