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combinations of laborers by the Federal Courts the particular importance of this decision in law is in the confirmation of these previous opinions. That a boycott is one of the most unreasonable forms of restraint of trade has long been recog nized in all jurisdictions. It would seem to be sufficiently obvious that as the complainants were engaged in interstate commerce the acts of the defendants complained of were in restraint of that trade. The chief importance of this decision bids fair to be political, however. It remains to be seen whether organized labor can get enacted by Congress, for its benefit in America, even more ex traordinary exemption from civil liability than it has succeeded recently in obtaining in England from Parliament. B. W. CONSTITUTIONAL LAW. (Discharge of Ser vant because of Membership in Labor Organiza tion.) U. S. Sup. Ct. — The loth section of the Act of Congress of October i, 1888, 25 Stat. 501, c. 1063, forbidding employers to threaten employes with loss of employment or to unjustly discrimi nate against any employe because of his member ship in a labor organization, was held invalid by the United States Supreme Court in Adair v. United States, 28 Sup. Ct. Rep. 277, as being in violation of the 5th Amendment to the Federal Constitution, declaring that no person shall be deprived of liberty or property without due process of law. The court holds that such liberty and right embraces the right to make contracts for the purchase and sale of labor and that the act in question constituted an unlawful invasion thereof. As to the suggestion that the law should be upheld as being within the power of Congress relating to interstate commerce, it holds that the relation of an employe to a labor organization can have no bearing in the eye of the law upon^the commerce which the employe may be called upon to assist in carrying on under the terms of his employment and that his fitness for labor and diligence in dis charge of his duties can not be held in any way dependable upon his membership or non-member ship in a labor union. Much unfair criticism has been directed by organized labor against this decision, and numer ous newspaper articles and headlines have chroni cled it as a judicial attack upon labor, and as an evidence of hostility on the part of the courts. As a matter of fact the question is not a new one, and the decision of the Supreme Court of the United States is entirely in harmony with numerous de cisions of the State Courts on similar statutes. Organized labor would hardly favor a statute which should deny to a workman, as an indi vidual, the right to quit an employment because

the employer employs some persons who were not members of a Union, or who were otherwise dis tasteful to him, and it can hardly demand that an employer shall be compelled by law to keep in his employment persons whom he does not desire, or to give his reasons for discharging them. ANDREW A. BRUCE. COMMERCE. (Power of Commission.) U. S. C. C., S. D., N. Y. — Considerable interest is taken in the decision of the United States Circuit Court in the case of Interstate Commerce Commission v. Harriman et al., 157 Fed. Rep. 432, on account of the prominence of the defendants and the notoriety attendant upon some of their recent financial and railroad operations. The proceeding arose out of the refusal of Messrs. Harriman and Kahn to answer certain questions propounded by the Inter state Commerce Commission under a resolution passed by it providing for investigation of opera tions in which these gentlemen were interested in connection with the Union Pacific and other rail roads. Several grounds of objection to the ques tions were urged by respondents, one of the most important of which was the contention that Con gress had no power to legislate on the matters under consideration and could not therefore inves tigate nor delegate to the Commission any power of investigation. The court held that notwith standing the fact that Congress might not have the power to punish malfeasance by officers of corporations engaged in interstate commerce, yet the matters here sought to be investigated were such as might tend to defeat the purposes of valid Federal legislation. To quote the language of the court: " No person or company can engage in any commercial occupation without capital and the management and investment thereof is as much a commercial instrumentality as is a locomotive or an engineer, and that the power of Congress ex tends over all instrumentalities of commerce is no longer doubtful. . . . To me it seems clear that financial regulation of corporations engaged in interstate commerce is a regulation of that commerce by regulating its most potent instru mentality." It was held that, with certain exceptions, respondents should be compelled to answer any of the questions propounded. CONSTITUTIONAL LAW. (Regulating Hours of Labor by Women.) U. S. Sup. Ct. — The Oregon law regulating hours of employment of women in laundries is held valid by the United States Supreme Court. The statute provides that no woman shall be employed in any mechani cal-establishment, factory, or laundry more than ten hours in any one day. The law was held con stitutional by the Oregon Supreme Court in State v. Muller, 85 Pac. Rep. 855 and the decision