Plant v. Woods, 176 Mass. - 492, 57 N.E. 1011 (1900)

Rule:

Where the plaintiffs have been injured by certain acts, and there is reason to believe that the defendants contemplate further proceedings of the same kind which will be likely still more to injure the plaintiffs, a bill in equity lies to enjoin the defendants.

Facts:

Defendant union conspired to compel plaintiff union’s members to join defendant. To carry out this purpose, defendant resolved to coerce by threatening loss of property by strikes and boycotts to induce the employers either to get plaintiff's members to ask for reinstatement in defendant or, that failing, then to discharge them. Plaintiff instituted a suit in order to enjoin defendant from doing the acts designed to force the plaintiff’s members. The trial court ruled in favor of plaintiff. Defendant sought review of the decision. 

Issue:

Under the circumstances, could the members of the defendant union be enjoined from doing the acts designed to force the plaintiff’s members to join defendant? 

Answer:

Yes.

Conclusion:

The court held that defendant interfered with plaintiff's members' right to dispose of their labor with full freedom. The acts complained of were calculated to cause damage to plaintiff's members, and did actually cause such damage. The acts were intentionally done for that purpose. Because there was no justifiable cause, the acts were malicious and unlawful. Defendant had no right to force other persons to join defendant. Defendant's acts did not come under the shelter of the principles of trade competition. Defendant's acts were without justification, and therefore were malicious and unlawful. The conspiracy thus to force plaintiff's members was unlawful. However, inasmuch as the association of the defendants was not a corporation, an injunction cannot be issued against it as such, but only against its members, their agents and servants.