United States v. Hutcheson

Supreme Court of the United States · 1941 · Labor Law

312 U.S. 219 (1941)

Updated August 1, 2026

Labor LawNorris-LaGuardiaantitrust exemptionlabor antitrust exemptionSherman ActClayton Act section 20Norris-LaGuardia Actlabor dispute

Facts

Anheuser-Busch contracted for construction of an additional facility, and Gaylord Container Corporation, its adjacent tenant, separately contracted for a new building. A long-running jurisdictional dispute existed between the Carpenters and the Machinists over machinery erection and dismantling jobs, and although Anheuser-Busch had agreements giving those jobs to the Machinists and requiring the Carpenters to arbitrate disputes, the indicted Carpenters officials insisted on the Carpenters' claim and refused arbitration. After the employer rejected their demand, the Carpenters struck against Anheuser-Busch and the construction companies, picketed Anheuser-Busch and Gaylord, and urged union members and their friends not to buy Anheuser-Busch beer. The indictment treated these peaceful union activities as a criminal combination and conspiracy under the Sherman Act.

Issue

Whether a union's use of conventional, peaceful strike, picketing, and boycott activities in a controversy with a rival union over particular jobs constitutes a criminal violation of the Sherman Act. More specifically, the question was whether such conduct remains unlawful under the Sherman Act when the Clayton Act and Norris-LaGuardia Act are read together.

Rule

Whether trade union conduct violates the Sherman Act must be determined by reading the Sherman Act, § 20 of the Clayton Act, and the Norris-LaGuardia Act together. If the conduct consists of the peaceful activities enumerated in § 20, and the union acts in its self-interest and does not combine with non-labor groups, that conduct is not to be considered or held a violation of any law of the United States, including the Sherman Act; the Norris-LaGuardia Act confirms that this protection is not limited to disputes involving only an immediate employer-employee relationship.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

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

In Cleveland, the Stone Fitters Local and the Metal Installers Guild dispute which craft should perform conveyor-installation work at a food-processing plant owned by Lakeshore Milling Cooperative. After the plant assigns the work to the rival union, the Stone Fitters peacefully strike, picket the plant entrance with signs saying the company is unfair to organized labor, and circulate leaflets urging the public not to buy the plant's packaged flour.

Federal prosecutors indict the Stone Fitters' officers under the Sherman Act, arguing the campaign restrains interstate trade in flour. Which is the best analysis?

Explanation. The majority held that courts must read the Sherman Act, § 20 of the Clayton Act, and the Norris-LaGuardia Act as a harmonizing text. Peaceful striking, peaceful picketing to communicate information, and peaceful appeals not to patronize are among the acts enumerated in § 20. When a union acts in its self-interest and does not combine with non-labor groups, those acts are not to be considered violations of any federal law, including the Sherman Act. The protection is not limited to wage-hour disputes.