The court ruled that the government had a right to regulate interstate commerce and ensure the operations of the Postal Service, along with a responsibility to "ensure the general welfare of the public."
Eugene V. Debs, president of the American Railway Union, had been involved in the Pullman Strike earlier in 1894 and challenged the federal injunction ordering the strikers back to work where they would face being fired. The injunction had been issued because of the violent nature of the strike. However, Debs refused to end the strike and was subsequently cited for contempt of court; he appealed the decision to the courts.
The main question being debated was whether the federal government had a right to issue the injunction, which dealt with both interstate and intrastate commerce and shipping on rail cars.
Justice David J. Brewer for a unanimous court held that the U.S. government had a right to regulate interstate commerce and ensure the operations of the Postal Service, along with a responsibility to "ensure the general welfare of the public." Brewer said the following in summing up the judgment:
We find in the opinion of the circuit court a quotation from the testimony given by one of the defendants[1] before the United States strike commission, which is sufficient answer to this suggestion:
As soon as the employees found that we were arrested, and taken from the scene of action, they became demoralized, and that ended the strike. It was not the soldiers that ended the strike. It was not the old brotherhoods that ended the strike. It was simply the United States courts that ended the strike. Our men were in a position that never would have been shaken, under any circumstances, if we had been permitted to remain upon the field, among them. Once we were taken from the scene of action, and restrained from sending telegrams or issuing orders or answering questions, then the minious of the corporations would be put to work. * * * Our headquarters were temporarily demoralized and abandoned, and we could not answer any messages. The men went back to work, and the ranks were broken, and the strike was broken up, * * * not by the army, and not by any other power, but simply and solely by the action of the United States courts in restraining us from discharging our duties as officers and representatives of our employees.
Whatever any single individual may have thought or planned, the great body of those who were engaged in these transactions contemplated neither rebellion nor revolution, and when in the due order of legal proceedings the question of right and wrong was submitted to the courts, and by them decided, they unhesitatingly yielded to their decisions. The outcome, by the very testimony of the defendants, attests the wisdom of the course pursued by the government, and that it was well not to oppose force simply by force, but to invoke the jurisdiction and judgment of those tribunals to whom by the constitution and in accordance with the settled conviction of all citizens is committed the determination of questions of right and wrong between individuals, masses, and states.
It must be borne in mind that this bill was not simply to enjoin a mob and mob violence. It was not a bill to command a keeping of the peace; much less was its purport to restrain the defendants from abandoing whatever employment they were engaged in. The right of any laborer, or any number of laborers, to quit work was not challenged. The scope and purpose of the bill was only to restrain forcible obstructions of the highways along which interstate commerce travels and the mails are carried. And the facts set forth at length are only those facts which tended to show that the defendants were engaged in such obstructions.
A most earnest and eloquent appeal was made to us in eulogy of the heroic spirit of those who threw up their employment, and gave up their means of earning a livelihood, not in defense of their own rights, but in sympathy for and to assist others whom they believed to be wronged. We yield to none in our admiration of any act of heroism or self-sacrifice, but we may be permitted to add that it is a lesson which cannot be learned too soon or too thoroughly that under this government of and by the people the means of redress of all wrongs are through the courts and at the ballot box, and that no wrong, real or fancied, carries with it legal warrant to invite as a means of redress the co-operation of a mob, with its accompanying acts of violence.
We have given to this case the most careful and anxious attention, for we realize that it touches closely questions of supreme importance to the people of this country. Summing up our conclusions, we hold that the government of the United States is one having jurisdiction over every foot of soil within its territory, and acting directly upon each citizen; that, while it is a government of enumerated powers, it has within the limits of those powers all the attributes of sovereignty; that to it is committed power over interstate commerce and the transmission of the mail; that the powers thus conferred upon the national government are not dormant, but have been assumed and put into practical exercise by the legislation of congress; that in the exercise of those powers it is competent for the nation to remove all obstructions upon highways, natural or artificial, to the passage of interstate commerce or the carrying of the mail; that, while it may be competent for the government (through the executive branch and in the use of the entire executive power of the nation) to forcibly remove all such obstructions, it is equally within its competency to appeal to the civil courts for an inquiry and determination as to the existence and character of any alleged obstructions, and if such are found to exist, or threaten to occur, to invoke the powers of those courts to remove or restrain such obstructions; that the jurisdiction of courts to interfere in such matters by injunction is one recognized from ancient times and by indubitable authority; that such jurisdiction is not ousted by the fact that the obstructions are accompanied by or consist of acts in themselves violations of the criminal law; that the proceeding by injunction is of a civil character, and may be enforced by proceedings in contempt; that such proceedings are not in execution of the criminal laws of the land; that the penalty for a violation of injunction is no substitute for and no defense to a prosecution for any criminal offenses committed in the course of such violation; that the complaint filed in this case clearly showed an existing obstruction of artificial highways for the passage of interstate commerce and the transmission of the mail,—an obstruction not only temporarily existing, but threatening to continue; that under such complaint the circuit court had power to issue its process of injunction; that, it having been issued and served on these defendants, the circuit court had authority to inquire whether its orders had been disobeyed, and, when it found that they had been, then to proceed under section 725, Rev. St., which grants power 'to punish, by fine or imprisonment, * * * disobedience, * * * by any party * * * or other person, to any lawful writ, process, order, rule, decree, or command,' and enter the order of punishment complained of; and, finally, that the circuit court having full jurisdiction in the premises, its finding of the fact of disobedience is not open to review on habeas corpus in this or any other court. Ex parte Watkins, [1830] USSC 16; 3 Pet. 193; Ex parte Yarbrough, [1884] USSC 81; 110 U. S. 651, 4 Sup. Ct. 152; Ex parte Terry, [1888] USSC 236; 128 U. S. 280-305, 9 Sup. Ct. 77; In re Swan[1893] USSC 267; 150 U. S. 637, 14 Sup. Ct. 225; U. S. v. Pridgeon, [1894] USSC 138; 153 U. S. 48, 14 Sup. Ct. 746.
We enter into no examination of the act of July 2, 1890 (26 Stat. 209), upon which the circuit court relied mainly to sustain its jurisdiction. It must not be understood from this that we dissent from the conclusions of that court in reference to the scope of the act, but simply that we prefer to rest our judgment on the broader ground which has been discussed in this opinion, believing it of importance that the principles underlying it should be fully stated and affirmed.
Significance
In Loewe v. Lawlor the Supreme Court stated that unions were in fact potentially liable for antitrust violations. In response Congress passed the Clayton Act of 1914 to take unions out of antitrust law. Debs would go on to lose another Supreme Court case in Debs v. United States.
↑ n.b. This is the US Strike Commission, Report on the Chicago Strike of June–July 1894 (GPO 1895) 143-144, §78
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References
Papke, David Ray. (1999) The Pullman Case: The Clash of Labor and Capital in Industrial America. Lawrence, Kansas: University Press of Kansas ISBN0-7006-0954-7
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