This section is from the book "The Law Of Contracts", by William Herbert Page. Also available from Amazon: Commercial Contracts: A Practical Guide to Deals, Contracts, Agreements and Promises.
The doctrine that relief of some sort will be given against a combination seeking to cause the breach of a contract, or interfere with a trade or business, is not limited to cases where relief is sought by an employe whose discharge is demanded or caused, nor to injunctions to prevent injury to business. While these are the commonest forms of injury and are therefore the cases most frequently presented for adjudication, they do not limit the doctrine. In a recent English case, A, a butcher, had employed nonunion men. X, a retail seller of meat, had been taking fine meat from A, though without any binding contract in advance to take it. The union demanded that A employ only union men. On A's refusal the union demanded that X refuse to deal with A, and ordered X's men to strike if X continued to buy meat from A. X accordingly discontinued his dealings with A. It was held that A could recover damages against the persons who by such threats induced X to discontinue his dealings with A.1 X, a trades-union committee, tried to compel the builders of a certain town to obey certain rules. A declined. X then tried to induce those who supplied A with material to refuse to continue to do so. B, one of such material men, declined to do this. X then induced Y, who had a contract with B to furnish material, to break such contract and refuse performance. B brought an action against X for damages. It was held that he could recover.2 An employer whose apprentices are under a contract not to join labor unions, may have an injunction against representatives of a union who, knowing of such a contract, seek to induce the apprentices to break their contract and join a union.3 An injunction has been granted on the application of a vendee, to enjoin striking employes of the vendor from preventing the vendor from performing his contract of sale. Thus a mining corporation A sold all its product of coal to a coal company B, which made contracts of sale to others in reliance on obtaining coal from A. By the terms of the contract A was not liable for failure to deliver, if caused by strikes. A strike in which strikers pre-vented other persons from working for A, prevented A from delivering coal. It was held that B could enjoin the strikers from interfering with A's business and preventing A from delivering coal to B.4
14 See obiter in Union Pacific Ry. v. Ruef. 120 Fed. 102.
15 Plant v. Woods, 176 Mass. 492; 79 Am. St. Rep. 330; 51 L. R. A. 339; 57 N. E. 1011. (See the dissenting opinion in this case for a statement of the opposite doctrine.) Gray v. Trades' Council,- Minn. - ; 63 L. R. A. 753; 97 N. W. 663.
16 Taff Vale Ry. v. Amalgamated Society of Railway Servants (1901), App. Cas. 426.
17 Southern Ry. v. Machinists' Local Union, 111 Fed. 49;; Vegelahn v. Gunter, 167 Mass. 92; 57 Am. St. Rep. 443; 35 L. R. A. 772; 44 N. E. 1077,
1 Quinn v. Leathern (1901), App. Cas. 495; affirming Leathern v. Craig, 2 Ir. Rep. (1899) 667.
2 Temperton v. Russell (1893). 1 Q. B. 715.
3 Flaeeus v. Smith, 199 Pa. St.
128; 85 Am. St. Rep. 779; 54 L. R. A. 640; 48 Atl. 894.
4 Chesapeake, etc., Co. v. Coke Co., 119 Fed. 942; Carroll v. Coal Agency Co., 124 Fed. 305.