"A boycott may be defined to be a combination of several persons to cause a loss to a third person by causing others against their will to withdraw from him their beneficial business intercourse through threats that, unless a compliance with their demands be made, the persons forming the combination will cause loss or injury to him; or an organization formed to exclude a person from business relations with others by persuasion, intimidation, and other acts, which tend to violence, and thereby cause him through fear of resulting injury to submit to dictation in the management of his affairs."1 A boycott is a criminal conspiracy,2 and, as ordinarily conducted, it gives a right of action to the party against whom such boycott is aimed.3 A boycott is unlawful, whether it is intended to prevent prospective customers from dealing with the person against whom the boycott is aimed,4 or whether it is intended to prevent him from obtaining the assistance of employes.5 A boycott is an unlawful means in itself, even though it is employed for a lawful purpose,6 such as securing improved labor conditions.7 Even if the competition between the parties is legitimate competition, the boycott can not be employed.8 A, a butcher, had employed non-union 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.9 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 materialmen, 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.10

4 170 N. Y. 315, 88 Am. St. Rep. 648, 68 L. R. A. 135, 63 N. E. 369.

5 See Sec. 1325, 1331.

1 Gray v. Building Trades Council, 91 Minn. 171, 103 Am. St. Rep. 477, 63 L. R. A. 753, 97 N. W. 663, 1118. For similar definitions see - .

District of Columbia. American Federation of Labor v. Buck's Stove

Co., 33 D. C. App. 83, 32 L. R. A. (N.S.) 748.

Iowa. Funck v. Farmers' Elevator Co., 142 la. 621, 24 L. R. A. (N.S.) 10S, 121 N. W. 53.

Massachusetts. Hoban v. Dempsey, 217 Mass. 166, L. R. A. 1915A, 1217, Ann. Cas. 1915C, 810, 104 N. E. 717.

Michigan. Baldwin v. Escanaba Liquor Dealers' Association, 165 Mich. 98, 130 N. W. 214.

Missouri Lohse Patent Door Co. v Fuelle, 215 Mo. 421, 128 Am. St. Rep. 492, 22 L. R. A. (N.S.) 607, 114 S. W. 997.

See, Solidarity of Interest as Basis of Legality of Boycotting, by F. H. Cook, 11 Yale Law Journal, 153.

2 State v. Stockford, 77 Conn. 227, 107 Am. St. Rep. 28, 58 Atl. 769; State v. Stewart, 59 Vt. 273, 59 Am. Rep. 710, 9 Atl. 559; Crump v. Commonwealth, 84 Va. 927, 10 Am. St. Rep. 896, 6 S. E. 620.

3Purington v. Hinchliff, 219 111. 159, 109 Am. St. Rep. 322, 2 L. R. A. (N.S.) 824, 76 N. E. 47; Funk v. Farmers Elevator Co., 142 Ia. 621, 24 L. R. A. (N.S.) 108, 121 N. W. 53.

4 Booth v. Burgess, 72 N. J. Eq. 181, 65 Atl. 226.

5 Iron Molders' Union v. Allis-Chal-mera Co., 166 Fed. 45, 20 L. R. A. (N.S.) 315; Willcutt v. Driscoll 200 Mass. 110, 23 L. R. A. (N.S.) 1236, 85

N. E. 897; Purvis v. United Brotherhood, 214 Pa. St. 348, 112 Am. St. Rep. 757, 12 L. R. A. (N.S.) 642, 63 Atl. 585.

6 State v. Glidden, 55 Conn. 46, 3 Am. St. Rep. 23, 8 Atl 890.

7 George Jonas Glass Co. v. Glass Bottle Blowers' Association, 77 N. J. Eq. 219, 41 L. R. A. (N.S.) 445, 79 Atl. 262.

8 My Maryland Lodge v. Adt, 100 Md. 238, 68 L. R. A. 752, 59 Atl. 721.

9Quinn v. Leathern [1901], App. Cas. 495 [affirming, Leathern v. Craig, 2 Ir. Rep. (1899), 667].

10Temperton v. Russell [1893], 1 Q. B. 715.