The action or suit may be brought by the employer whose business is threatened. The threatened strike, or boycott, may be intended to compel him to acquiesce in certain arrangements for remuneration, hours of labor, and the like, or to compel him to employ only members of the union, and in this last case the employer is occasionally in no way really involved, since the real conflict is between rival unions, although the employer is likely to be one of the real victims. The remedy of injunction is often sought in such cases, as, if it can be obtained, it is the most efficient remedy for preventing a wreck of business. No injunction can be given against a mere strike, if peaceable and not connected with a boycott.1 Injunction has, however, been granted restraining employes from interfering with the performance of a contract on the part of their employer, though such interference was peaceable, where the employes did not quit work in good faith.2 An employer whose employes or 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

1 England. Taff Vale Ry. v. Amalgamated Society of Railway Servants [1901], A. C. 426.

United States. Niles-Bement-Pond Co. v. Iron Holders' Union, 246 Fed. 851.

California. Goldberg v. Stablemen's Union, 149 Cal. 429, 117 Am. St. Rep. 145, 8 L. R. A. (N.S.) 460, 86 Pac. 806.

Kentucky. Underbill v. Murphy, 117 Ky. 640, 78 S. W. 482.

Massachusetts. Vegelahn v. Gunter. 167 Mass. 92, 57 Am. St. Rep. 443. 35 L. R. A. 772, 44 N. E. 1077.

Michigan. Beck v. Protective Union, 118 Mich. 497, 74 Am. St. Rep. 421, 42 L. R. A. 407, 77 N. W. 13.

Minnesota. Minnesota Stove Co. v. Cavanaugh, 131 Minn. 458, 155 N. W. 638.

Missouri. Hamilton Brown Shoe Co. v. Saxey. 131 Mo. 212, 52 Am. St. Rep. 622, 32 S. W. 1106.

Nevada. Branson v. Industrial Workers of the World, 30 Nev. 270, 95 Pac. 354.

New Jersey. Jersey City Printing Co. v. Cassidy, 63 N. J. Eq. 759, 53 Atl. 230.

See. The Taff Vale Case. by Jno. G. Steffee, 37 American Law Review, 385.

2 England. Taff Vale Ry. v. Amalgamated Society of Railway Servants [1901], A. C. 426.

Kentucky. Underhill v. Murphy, 117 Ky. 640, 78 S. W. 482.

Massachusetts. Vegelahn v. Gunter, 167 Mass. 92, 57 Am. St. Rep. 443, 35 L. R. A. 772, 44 N. E. 1077.

Michigan. Beck v. Protective Union, 118 Mich, 497. 74 Am. St. Rep. 421, 42 L. R. A. 407, 77 N. W. 13.

Missouri. Hamilton Brown Shoe Co. v. Saxey. 131 Mo. 212, 52 Am. St. Rep. 622. 32 S. W. 1106.

New Jersey. Jersey City Printing Co. v. Cassidy, 63 N. J. Eq. 759, 53 Atl. 230.

3 Max Ams Machine Co. v. International Association of Machinists, 92 Conn. 297, 102 Atl. 706.

4 Max Ams Machine Co. v. International Association of Machinists, 92 Conn. 297, 102 Atl. 706.

Associations of employes may also be enjoined from ordering,4 or soliciting,5 employes under contract to break their contracts.

An injunction binds members of an association or union who have knowledge of such injunction, although they are not parties to the action.6 They may be guilty of contempt of court, accordingly, if they violate such injunction.7

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 prevented 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.8

1 Wabash Ry. v. Hannahan, 121 Fed. 563; Gray v. Puilding Trades Council, 91 Minn. 171, 103 Am. St. Rep. 477, 63 L. R. A. 753, 97 V W. 663, 1118.

2 In re Lennon, 166 U. S. 548, 41 L. ed. 1110.

3Hitchman Coal & Coke Co. v. Mitchell, 245 U. S. 229. 63 L. ed. 260, L. R. A. 1918C, 497; Flaccus v. Smith, 199 Pa. St. 128, 85 Am. St. Pep. 779, 54 L. R. A. 640, 48 Atl. 894.

4 Taff Vale Ry. v. Amalgamated Society of Railway Servants [1901], App. Cas. 426.

5Hitchman Coal & Coke Co. v. Mitchell, 245 U. S. 229, 62 L. ed. 260, L. R. A. 1918C, 497; Southern Ry. v. Machinists' Local Union, 11 Fed. 49; Vegelahn v. Gunter, 167 Mass. 92, 57 Am. St. Rep. 443, 35 L. R. A. 772, 44 N. E. 1077.

6 People v. Marr, 181 N. Y. 463, 106 Am. St. Rep. 562, 74 N. E. 431.

7 People v. Marr, 181 N. Y. 463, 106 Am. St. Rep. 562, 74 N. E. 431.

8 Chesapeake, etc., Co. v. Coke Co.. 119 Fed. 942; Carroll v. Coal Agency Co., 124 Fed. 305.

The question of the right to equitable relief has been discussed in connection with the various types of wrongful means which may be employed, or wrongful purposes for which proper means are employed.9

Injunction will issue to restrain interference with other types of contracts.10

Injunction will issue to prevent the use of banners in front of a place of business, declaring that the owner is "unfair," because he persists in doing certain of the work himself.11 It will issue to prevent X from buying from A property which, to X's knowledge, A has agreed to sell to B.12