In re Debs

Brief Fact Summary.

The leader of American Railway Union, Eugene V. Debs, was convicted of contempt of court for ignoring an injunction ordering the union workers back to work. He challenged his conviction, arguing that the federal courts did not have the authority to issue the injunction.

Synopsis of Rule of Law.

Federal courts may enjoin a strike where it interferes with interstate commerce and the federal postal service.

Facts.

The American Railway Union was on strike. A federal court issued an injunction ordering the union members to return to work. The injunction was based on the grounds that the strike was affecting interstate commerce and the federal postal service. The 22 railroad companies affected by the strike carried millions of passengers to and from Chicago, carried millions of tons of freight, carried the federal mail, and could be used to transport federal trops and equipment if necessary. The union ignored the injunction and Eugene V. Debs was one of the union leaders found in contempt and sentenced to jail time. The leaders argued that the federal court did not have the authority to issue the injunction. The Supreme Court decided the case.

Issue.

Can federal courts enjoin a strike that interferes with interstate commerce and the federal postal service?

Held.

(Brewer, J.) Yes. Federal courts may enjoin a strike where it interferes with interstate commerce and the federal postal service. The Constitution grants the federal government the authority to regulate interstate commerce and maintain a postal service. Therefore, the federal government may prevent interference with interstate commerce and the postal system. It may do so through legislative action, executive enforcement, or judicial intervention. If a court acts within this authority and its order is ignored, it may enforce its own orders through its contempt powers. This action does not require a trial by jury, as the court is not enforcing criminal laws, but its own order.

Discussion.

Justice Brewer’s opinion rests on the assumption that in order to prevent interference with interstate commerce or the federal mail. the executive branch could use force and the judiciary could issue injunctive relief without a statutory cause of action. Along these lines, Congress could have used military force to break the strike as well, given its authority under Article I,§ 8, of the Constitution.