In re Charge to Grand Jury
1894 U.S. Dist. LEXIS 67, 62 F. 828 (1894)
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Rule of Law:
A concerted action by labor organizers to compel employees to quit their jobs, through threats or penalties, with the effect of obstructing the U.S. mail or interstate commerce, constitutes an illegal conspiracy under federal law unless the leaders are acting in good faith within lawful authority granted by the employees.
Facts:
- A widespread work stoppage occurred among employees of several railroads.
- The striking employees were members of a labor organization and acted under the direction of their leaders.
- The strike resulted in the obstruction and retardation of trains carrying the U.S. mail.
- The strike also resulted in the stoppage of trains transporting passengers and goods in interstate commerce.
- There were allegations that replacement employees, hired to take the place of the strikers, were prevented from working through threats, intimidation, or violence.
Procedural Posture:
- A federal grand jury was convened in the Northern District of Illinois to investigate potential federal crimes arising from a widespread railroad strike.
- U.S. District Judge Grosscup delivered this charge, or set of legal instructions, to the grand jury to guide its investigation.
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Issue:
Does a concerted effort by labor organizers to induce a widespread railroad employee strike, which results in the obstruction of the U.S. mail and interstate commerce, constitute a criminal conspiracy punishable under federal law?
Opinions:
Majority - Grosscup, District Judge
Yes, a concerted effort by labor organizers to induce a widespread strike that obstructs mail and interstate commerce can constitute a criminal conspiracy. While an individual's right to quit work is an 'imperishable right of a freeman,' and workers may lawfully organize and choose leaders, these rights are not absolute. Federal law criminalizes conspiracies to obstruct the mail and to restrain interstate commerce. A conspiracy exists if two or more people agree to use threats, intimidation, or violence to compel employees to quit and prevent replacements from working, with the effect of stopping mail or interstate transport. If labor leaders orchestrate such an action, the burden falls on them to prove they were acting with lawful authority from the employees and in good faith. If they used their leadership position as a 'guise to advance personal ambition or satisfy private malice,' their actions are unlawful and constitute a criminal conspiracy.
Analysis:
This charge to the grand jury represents a pivotal application of federal law against organized labor in the late 19th century. By framing a large-scale strike as a potential criminal conspiracy to obstruct interstate commerce and the mail, the court provided a powerful legal weapon for the federal government to suppress labor movements. This approach subordinated the right to collective action to the imperative of maintaining the free flow of commerce, setting a precedent for the use of federal court injunctions and criminal charges to break major strikes. The decision solidified the judiciary's role as an enforcer of commercial interests against the growing power of unions, a stance that would dominate American labor law until the legislative reforms of the 20th century.
