Duplex Printing Press Co. v. Deering

Supreme Court of the United States · 1921 · Labor Law

254 U.S. 443 (1921)

Updated August 1, 2026

Labor LawClayton ActinjunctionsSherman Actsecondary boycottprimary boycottClayton Act § 6Clayton Act § 20

Facts

Duplex Printing Press Co., a Michigan manufacturer operating an open shop, sold large printing presses in interstate commerce, including to customers in New York. Defendants were union representatives in New York affiliated with a larger machinists' organization that sought to force complainant to unionize its Michigan factory and adopt the closed shop, the eight-hour day, and union wages. None of the defendants was or had been complainant's employee, and the complained-of acts concerned not the factory itself but the installation and use of presses by complainant's customers. Defendants carried out an elaborate secondary boycott by warning and threatening customers, threatening sympathetic strikes in other trades, pressuring truckers and repair shops, and inducing others to stop work so as to obstruct delivery, installation, and sale of complainant's presses in interstate commerce.

Issue

Whether defendants' campaign of threats, coercion, and inducement directed at complainant's customers and other neutral parties to force complainant to yield in a labor dispute violated the Sherman Act, and whether §§ 6 and 20 of the Clayton Act barred a federal injunction against that conduct. More specifically, the question was whether the Clayton Act protected this secondary boycott by union members who were not in a proximate employment relation with complainant.

Rule

A combination that restrains interstate commerce by coercively pressuring neutral customers or others to stop dealing with a trader through a secondary boycott violates the Sherman Act. Sections 6 and 20 of the Clayton Act do not authorize or immunize such conduct; the § 20 exemptions are confined to persons proximately and substantially concerned as parties to an actual dispute over the terms or conditions of their own employment, and only for peaceful and lawful conduct within that dispute.

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Prairie Forge Equipment, based in Indiana, sells industrial cutters to buyers in Ohio and Pennsylvania. Members of a metalworkers' union in Pittsburgh, none of whom work for Prairie Forge, pressure local warehouses and trucking firms to stop handling Prairie Forge machines and warn customers that other unionized trades will walk off the job if the machines are accepted.

If Prairie Forge seeks a federal injunction under the antitrust laws, what is the strongest argument for granting it?

Explanation. The majority treated a combination that coercively pressures neutral customers and other neutrals to stop dealing with a trader as a secondary boycott violating the Sherman Act when it obstructs interstate commerce. Violence is not required; peaceful persuasion intended to restrain interstate commerce may also fall within the Act. Section 6 does not create blanket labor immunity, and the mere existence of a wage dispute does not remove the conduct from the antitrust laws.