An employer whose employes are induced to leave his employment by the wrongful interference of an organization or association, may recover damages against the person who thus induces them to leave their employment.1 Punitive damages may be allowed.2 If the employer brings an action for an injunction and for damages, and he shows his right to an injunction, he is entitled to at least nominal damages.3 The fact that the employer has agreed with the labor union to employ only persons acceptable to such union, does not relieve the union from liability for damages to one whose discharge it causes by its wrongful interference.4

Damages can be recovered for wrongful interference with other types of contracts in jurisdictions in which such act is recognized as a wrong.5

9 See, Injunction as a Remedy for the Boycott, by H. S. Bullard, 3 Yale Law Journal, 211; and Legal Restraint of Labor Strikes, by Wm. P. Aiken, 4 Yale Law Journal, 13.

See Sec. 2412 et seq.

10 National Phonograph Co. v. Edison-Bell Consolidated Phonograph Co. [1908], 1 Ch. 335; Friedberg v. McClary, 173 Ky. 579, L. P. A. 1917C, 777, 191 S. W. 300.

11 Roraback v. Motion Picture Machine Operators' Union, 140 Minn. 481, 3 A. L. R. 1290, 168 N. W. 766, 169 N. W. 529.

12Friedberg v. McClary, 173 Ky. 579, L. R. A. 1917C. 777. 191 S. W. 300.

1Max Ams Machine Co. v. International Association of Machinists. 92 Conn. 297. 102 Atl. 706; Employing

Printers' Club v. Dr. Blosser Co., 122 Ga. 509, 106 Am. St. Rep. 137, 69 L. R. A. 90, 50 S. E. 353; Martineau v. Foley, 225 Mans. 107, 1 A. L. R. 1145, 113 N. E. 1038.

See, The Danbury Hatters Case: Its Possible Effect on Labor Unions, by Theodor Megaarden, 49 American Law Review. 417.

2Wyeman v. Deady, 79 Conn. 414, 118 Am. St. Rep. 152, 65 Atl. 129.

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

4Berrv v. Donovan. 188 Mass. 353, 5 L. R. A. (N.S.) 899, 74 N. E. 603.

5 National "Phonograph Co. v. Edison-Bell Consolidated Phonograph Co. [1908], Ch. 335.

See Sec. 2426, 2428 and 2429.