Lawlor v. Loewe, 235 U.S. 522 (1915)

Author: U.S. Supreme Court

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Lawlor v. Loewe, 235 U.S. 522 (1915)

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Lawlor v. Loewe

No. 358

Argued December 10, 11, 1914
Decided January 5, 1915
235 U.S. 522



Irrespective of compulsion or even agreement to observe its intimation, the circulation of a "we don’t patronize" or "unfair" list manifestly intended to put the ban upon those whose names appear therein, among an important body of possible customers, combined with a view to joint action and in anticipation of such reports, is within the prohibition of the Anti-Trust Act of July 2, 1890, if it is intended to restrain and does restrain commerce among the states. Eastern States Retail Lumber Dealers Association v. United States, 234 U.S. 600.

This Court agrees with the courts below that the action of the unions and associations to which defendants belonged in regard to the use and circulation of "we don’t patronize" and "unfair dealer" lists, boycotts, union labels, and strikes, amounted to a combination and conspiracy forbidden by the Anti-Trust Act of July 2, 1890.

In this case, held that the trial court properly instructed the jury to the effect that defendants, members of labor unions who paid their dues and continued to delegate authority to their officers to unlawfully interfere with the interstate commerce of other parties, are jointly liable with such officers for the damages sustained by their acts.

Members of unions and associations are bound to know the constitutions of their societies, and, on the evidence in this case, the jury might well find that the defendants who were members of labor union knew how the words of the constitutions of such unions had been construed in the act.

The use in this case of the word "proof" by the trial judge in its popular way for "evidence" held, in view of the caution by the judge, not to have prejudiced the defendants.

A verdict for damages resulting from an illegal combination in restraint of interstate trade under the Anti-Trust Act of 1890 may include damages accruing after commencement of the suit but as the consequence of acts done before and constituting part of the cause of action declared on.

In this case, introduction of newspapers was not improper to show publicity in places and directions to bring notice home to defendants and to prove intended and detrimental consequences of the acts complained of.

Letters from customers of a boycotted manufacturer, giving the boycott as reason for ceasing to deal with him, held admissible in this case.

209 F. 721 affirmed.

The facts in this case, which is known as the "Danbury Hatters’" case, involving the validity of a verdict for damages resulting from a combination and conspiracy in restraint of trade under § 7 of the Anti-Trust Act, are stated in the opinion.


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Chicago: U.S. Supreme Court, "Syllabus," Lawlor v. Loewe, 235 U.S. 522 (1915) in 235 U.S. 522 235 U.S. 523–235 U.S. 533. Original Sources, accessed March 23, 2023,

MLA: U.S. Supreme Court. "Syllabus." Lawlor v. Loewe, 235 U.S. 522 (1915), in 235 U.S. 522, pp. 235 U.S. 523–235 U.S. 533. Original Sources. 23 Mar. 2023.

Harvard: U.S. Supreme Court, 'Syllabus' in Lawlor v. Loewe, 235 U.S. 522 (1915). cited in 1915, 235 U.S. 522, pp.235 U.S. 523–235 U.S. 533. Original Sources, retrieved 23 March 2023, from