Truax v. Corrigan

Supreme Court of the United States · 1921 · Federal Courts

Federal CourtsFourteenth AmendmentDue ProcessEqual ProtectionState Court Reviewinjunctionlabor disputepicketing

Facts

Plaintiffs operated the English Kitchen restaurant in Bisbee, Arizona. After a labor dispute over terms and conditions of employment, defendants, who were former employees and union members, struck and allegedly conspired to injure plaintiffs' business by picketing in front of the restaurant, loudly denouncing it as unfair, distributing handbills containing abusive and libelous statements about plaintiffs, employees, and customers, and threatening would-be patrons and any purchaser of the business. Plaintiffs alleged the campaign reduced their annual business from more than $55,000 to $12,000, that defendants were insolvent, and that Arizona Paragraph 1464 was being used to prevent injunctive relief. The complaint sought temporary and permanent injunctions, asserting the statute, if it legalized defendants' conduct, violated the Fourteenth Amendment.

Issue

Whether Arizona Paragraph 1464, as construed by the Arizona Supreme Court to deny injunctive relief against defendants' strike-related campaign of picketing, libel, abuse, threats, and obstruction, violated the Fourteenth Amendment. More specifically, the Court considered whether that application deprived plaintiffs of property without due process of law and denied them the equal protection of the laws.

Rule

A business and the owner's free access for employees, owners, and customers to the place of business are property rights protected by the Fourteenth Amendment. Intentional injury to those rights by a concerted campaign using unlawful means such as libelous and abusive attacks, threats, and obstructive picketing is a tort and conspiracy; a state may not constitutionally make such wrongs lawful or practically remediless, nor may it deny injunctive relief against such conduct to one class of victims while allowing that remedy to others under like circumstances in the same jurisdiction.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, Maya Patel owns a bakery. Her complaint in Arizona state court alleges that former employees, backed by a local guild, paced within a few feet of the entrance all day, shouted accusations audible down the block, distributed flyers containing false accusations about Maya and her customers, and warned patrons that anyone entering would be publicly shamed; the defendants demur, and the Arizona Supreme Court affirms dismissal by characterizing the conduct as mere peaceful publicity under a state labor statute.

If Maya seeks review in the U.S. Supreme Court, which approach best follows the governing doctrine?

Explanation. When a federal right is alleged to have been denied by a state-court judgment, and the constitutional issue turns on facts set out in the pleadings and admitted by demurrer, the Supreme Court may analyze those facts for itself and draw its own inferences about their constitutional significance. It remains bound by the state court's construction of the state statute, but not by the state court's characterization of the admitted conduct for federal constitutional purposes.