Vegelahn v. Guntner, 167 Mass. 92 (1896) is a United States labor law

United States labor law

United States labor law is a heterogeneous collection of state and federal laws. Federal law not only sets the standards that govern workers' rights to organize in the private sector, but also overrides most state and local laws that attempt to regulate this area. Federal law also provides more...

 decision from the Supreme Judicial Court of Massachusetts. It is noted for its famous dissent, written by Oliver Wendell Holmes, Jr., rather than its majority opinion.

Facts

The union had picketed in front of the employer's business with the object of persuading current employees and job applicants to not enter the building. The union also picketed to pressure workers to break employment contracts with the company. The objective was to force higher wages. The company successfully sought an injunction in court, under the doctrine of intentional interference with contract, alleging that the union was tort

Tort

A tort, in common law jurisdictions, is a wrong that involves a breach of a civil duty owed to someone else. It is differentiated from a crime, which involves a breach of a duty owed to society in general...

iously interfering with the relations between management and worker. In this era employers frequently resorted to state and federal courts to get restraining orders and injunctions to stop picketing, strikes, and boycotts.

Judgment

On appeal from the trial court, Justice Allen held that the coercion and intimidation found to have occurred interfered with the right of an employer to hire whom it pleases, and the right of workers to enter into employment. The court ruled that the union was guilty of an intentional tort.

Justice Holmes disagreed, equating the use of collective force by workers to the corporate use of force to compete.
This was one of the very first occasions when any judge of prominence had made such a declaration.

Significance

The Vegelahn case was decided in 1896, in a decade when immigrant workers were taking native Americans' jobs and were unionizing, and when the public had witnessed violent and far-flung labor unrest: with the Pullman Strike

Pullman Strike

The Pullman Strike was a nationwide conflict between labor unions and railroads that occurred in the United States in 1894. The conflict began in the town of Pullman, Illinois on May 11 when approximately 3,000 employees of the Pullman Palace Car Company began a wildcat strike in response to recent...

, the Homestead

Homestead, Pennsylvania

Homestead is a borough in Allegheny County, Pennsylvania, USA, in the "Mon Valley," southeast of downtown Pittsburgh and directly across the river from the city limit line. The borough is known for the Homestead Strike of 1892, an important event in the history of labor relations in the United...

, Pennsylvania violence between steel workers and Carnegie Steel, and the Haymarket

Haymarket affair

The Haymarket affair was a demonstration and unrest that took place on Tuesday May 4, 1886, at the Haymarket Square in Chicago. It began as a rally in support of striking workers. An unknown person threw a dynamite bomb at police as they dispersed the public meeting...

riot in Chicago. It would be another twenty-five years before the law would catch up to Holmes's dissent, with the passage of the federal Anti-Injunction Act (Norris-LaGuardia Act).