Carpenters v. Scott
463 U.S. 825 (1983)
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Rule of Law:
42 U.S.C. § 1985(3) does not provide a cause of action for conspiracies motivated by economic or commercial animus. Furthermore, a § 1985(3) claim for a conspiracy to infringe upon First Amendment rights requires proof of state involvement, as those rights are protected only against governmental interference.
Facts:
- A. A. Cross Construction Co., Inc. (Cross) contracted with the Department of the Army to build a pumping station near Port Arthur, Texas.
- Cross hired its employees for the project without regard to their union membership, which was contrary to the practice of many local employers.
- Cross employees were warned by local residents that the company's nonunion hiring practice was a matter of serious concern in the area and could lead to trouble.
- On January 15, 1975, the Executive Committee of the Sabine Area Building and Construction Trades Council discussed a protest against Cross's hiring practices.
- On January 17, 1975, a large group, including union members, gathered at the construction site.
- Several truckloads of men from this gathering drove onto the site, where they physically assaulted Cross employees Scott and Matthews and destroyed construction equipment.
- The assailants threatened continued violence if the nonunion workers did not leave the area or agree to union policies.
- The violence and vandalism caused construction delays that resulted in Cross defaulting on its contract with the Army.
Procedural Posture:
- Scott, Matthews, and A. A. Cross Construction Co., Inc. sued the Sabine Area Building and Trades Council and several local unions in the U.S. District Court for the Eastern District of Texas.
- After a trial, the District Court found for the plaintiffs, entering a permanent injunction and awarding damages against eleven local unions.
- The defendant unions appealed to the U.S. Court of Appeals for the Fifth Circuit.
- The Court of Appeals, sitting en banc, affirmed the judgment against three of the unions, finding that § 1985(3) reached conspiracies motivated by economic bias and did not require state action.
- The defendant unions (petitioners) successfully sought a writ of certiorari from the U.S. Supreme Court.
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Issue:
Does a conspiracy by union members to violently assault non-union workers, motivated by economic opposition to non-union labor, constitute a deprivation of 'equal protection of the laws' or 'equal privileges and immunities' actionable under 42 U.S.C. § 1985(3)?
Opinions:
Majority - Justice White
No. A conspiracy motivated by economic animus against non-union workers does not fall within the scope of 42 U.S.C. § 1985(3). First, the Court concluded that an alleged conspiracy to infringe First Amendment rights, such as the right of association, is not a violation of § 1985(3) unless it is proved that the State is involved in the conspiracy or that the aim of the conspiracy is to influence state activity. The First and Fourteenth Amendments are restraints on government action, not private conduct. While Griffin v. Breckenridge held that § 1985(3) could reach purely private conspiracies, it did so in the context of rights protected against private encroachment, like the right to travel and Thirteenth Amendment rights, not rights protected only against state action. Second, and more dispositively, the Court held that the statute’s requirement of a “class-based, invidiously discriminatory animus” was not met. The legislative history of the Ku Klux Klan Act of 1871, from which § 1985(3) derives, shows it was intended to combat racial animus against African Americans and their supporters, not conspiracies based on economic, commercial, or anti-union bias. Extending the statute to cover economic disputes would federalize labor conflicts, a domain Congress has addressed through other specific statutes like the National Labor Relations Act.
Dissenting - Justice Blackmun
Yes. The Ku Klux Klan Act was intended to provide a federal remedy for politically and economically vulnerable classes facing mob violence when local law enforcement is unable or unwilling to protect them. The majority fundamentally misinterprets the statute and its history. The 'equal protection' language in § 1985(3) was intended to limit its scope to conspiracies with a discriminatory animus, not to import a state-action requirement. Griffin correctly established that the statute reaches purely private conspiracies, and the Court's new state-involvement requirement for certain rights is an unjustified retreat. Furthermore, the class of nonunion workers qualifies for protection. The 42nd Congress was concerned with vulnerable groups, including economic migrants who were targeted by the Klan. In a self-professed 'union town,' nonunion workers were a distinct class targeted for their economic association and were vulnerable to precisely the kind of mob violence the Act was designed to prevent.
Analysis:
This decision significantly narrowed the scope of 42 U.S.C. § 1985(3), which had been interpreted broadly in Griffin v. Breckenridge. The Court established two critical limitations: first, that claims based on rights that are only protected against state infringement (like most First and Fourteenth Amendment rights) must show state involvement. Second, it excluded conspiracies motivated by purely economic or commercial animus from the 'class-based, invidiously discriminatory animus' requirement. This ruling effectively removes most labor disputes, union-related violence, and commercial conflicts from the statute's reach, reinforcing the idea that § 1985(3) is primarily a remedy for discrimination based on immutable characteristics like race, not economic or political disagreements.
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