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Plant v. Woods
Massachusetts Supreme Judicial Court
57 N.E. 1011 (1900)
Union 257, Painters and Decorators of America (the Baltimore union) (defendants) was affiliated with a national organization headquartered in Baltimore, Maryland. In 1897, several members of the Baltimore union withdrew to form a new painters’ union (the Lafayette union) (plaintiffs), which was affiliated with a different organization headquartered in Lafayette, Indiana. In September 1898, the Baltimore union declared painters who were not in the Baltimore union to be “non-union men.” Members of the Baltimore union attempted to persuade nonmember painters—including members of the Lafayette union—to join the Baltimore union, occasionally using threats and intimidation if peaceful methods failed. On October 7, 1898, the Baltimore union voted to boycott, strike at, or threaten to strike at any workplace that employed members of the Lafayette union. In carrying out this plan, the Baltimore union sought to compel members of the Lafayette union to either join the Baltimore union or risk losing their jobs. The Springfield, Massachusetts, branch of the Lafayette union sought and was granted an injunction against the Baltimore union. The Baltimore union appealed, arguing that there was nothing illegal about workers agreeing to stop working at a coordinated time and thus that boycotts and strikes were not inherently illegal.
Rule of Law
Holding and Reasoning (Hammond, J.)
Dissent (Holmes, C.J.)
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