Commonwealth v. Hunt

Early Ruling on Labor Unions

Lemuel Shaw, Chief Justice of the Massachusetts Supreme Court
Lemuel Shaw, Chief Justice of the Massachusetts Supreme Court. Public Domain Image. Harvard University Library, Weissman Preservation Center.

Commonwealth v. Hunt was a Massachusetts Supreme Court case that set a precedent in its ruling on labor unions. Previous to the ruling on this case, whether or not labor unions were actually legal in America was not clear. However, the court ruled in March, 1842 that if the union was created legally and used only legal means to meet its goals, then it was in fact legal. 

Facts of Commonwealth v. Hunt

This case centers around the legality of early labor unions.

Jeremiah Home, a member of the Boston Society of Journeymen Bootmakers, refused to pay a fine for violating the group's rules in 1839. The society persuaded Home's employer to fire him because of this. As a result, Home brought charges of criminal conspiracy against the society.

Seven leaders of the society were arrested and tried for "unlawfully ... designing and intending to continue, keep, form and unite themselves into a club..., and make unlawful by-laws, rules, and orders among themselves and other workmen." Even though they weren't accused of violence or malicious intent against the business in question, their by-laws were used against them and it was argued that their organization was a conspiracy. They were found guilty in a municipal Court in 1840. As the judge stated, the "common law as inherited from England prohibited all combinations in restraint of trade." They then appealed to the Massachusetts Supreme Court.

Massachusetts Supreme Court Decision

Upon appeal, the case was seen by Massachusetts Supreme Court led by Lemuel Shaw, a highly influential jurist of the era. Despite shaky precedents he decided in favor of the Society, claiming that even though the group had the ability to diminish a businesses' profits, they are not a conspiracy unless they used methods that were illegal or violent to achieve their ends.

Significance of the Ruling

With Commonwealth, individuals had been given the right to organize into trade unions. Previous to this case, unions were seen as conspiracy organizations. However, Shaw's ruling made it clear that they were in fact legal. They were not considered conspiracies or illegal, and instead seen as a necessary offshoot of capitalism. In addition, unions could require closed shops. In other words, they could require that individuals who work for a particular business were part of their union. Finally, this important court case ruled that the ability not to work, or in other words to strike, was legal as done in a peaceful way.

According to Leonard Levy in The Law of the Commonwealth and Chief Justice Shaw, his decision also had implications for the future relationship of the judicial branch in cases like this. Instead of picking sides, they would try and remain neutral in the struggle between labor and business.

Interesting Facts

  • Massachusett's Supreme Court Chief Justice Lemuel Shaw was extremely influential in not only setting state law but also establishing key federal precedents during his thirty years on the court. As Oliver Wendell Holmes, Jr. stated, "Few have lived who were [Shaw's] equal in their understanding of the grounds of public policy to which all laws must be ultimately referred.
  • Shaw's decision in Brown v. Kendall established the necessity of proving negligence for the purpose of imposing liability for accidental injury.
  • Shaw's daughter Elizabeth married Herman Melville, the author of Moby Dick. Melville dedicated his novel Typee to Shaw.
  • Robert Rantoul, Jr., the lawyer who represented the Boston Society of Journeymen Bootmakers, was a prominent Democrat who would later be elected to fill Daniel Webster's Senatorial seat until Rantoul's death in 1852.
  • Rantoul was a director of the Illinois Central Railroad. The town of Rantoul, Illinois was laid out in 1854 for the Illinois Central Railroad and named after him due to his untimely death.

Sources:

Foner, Philip Sheldon. History of the Labor Movement in the United States: Volume One: From the Colonial Times to the Founding of the American Federation of Labor. International Publishers Co. 1947.

Hall, Kermit and David S. Clark. The Oxford Companion to American Law. Oxford University Press: 2 May 2002.

Levy, Leonard W. The Law of the Commonwealth and Chief Justice Shaw. Oxford University Press: 1987.