Truax v. Corrigan
Truax v. Corrigan is a significant Supreme Court case from 1915 that addressed the tension between labor rights and property rights. The case arose in Arizona, where a law was enacted to protect labor union strikers from injunctions issued by courts, which were often seen as biased towards business interests. A business owner challenged this law after suffering losses due to a picket line established by striking workers. The Supreme Court, in a 5-4 decision led by Chief Justice William H. Taft, ruled that the Arizona statute was unconstitutional under the Fourteenth Amendment, arguing that it violated due process and equal protection by unfairly favoring employee disputes over other types of conflicts.
The ruling underscored the Court's willingness to limit state experiments in labor relations, prompting dissent from justices like Oliver Wendell Holmes and Louis D. Brandeis, who defended the state's right to enact such protective measures. The case is often cited in discussions about the balance between labor rights and business interests, highlighting the complexities of legal interpretations regarding economic activities and individual rights. Ultimately, Truax v. Corrigan remains a pivotal moment in understanding the evolving legal landscape surrounding labor relations in the United States.
Truax v. Corrigan
Date: December 19, 1921
Citation: 257 U.S. 312
Issues: Injunctions; labor
Significance: The Supreme Court, which typically took a conservative, probusiness, antilabor stance while William H. Taft was chief justice, struck down a state law protecting strikers against injunctions.
Chief Justice William H. Taft wrote the opinion for the 5-4 majority, striking down an Arizona law that protected labor union strikers from injunctions although not from suits for damages. Arizona and some other states sought to protect strikers from injunctions issued by conservative, probusiness courts. The Arizona courts upheld the statute in the face of a challenge from a business owner who lost half his customers while being picketed. The Supreme Court struck the Arizona statute on Fourteenth Amendment grounds. Taft held that the statute violated due process in that it deprived the owner of his property and equal protection in that it singled out employer-employee disputes for special treatment. Justice Oliver Wendell Holmes attacked the use of the Fourteenth Amendment to limit state experimentation. Justice Louis D. Brandeis dissented, setting out the legal and historical basis for the statute. Justice Mahlon Pitney was joined in a dissent by Justice John H. Clarke attacking all of the majority’s conclusions.
