Law School Case Brief
Truax v. Corrigan - 257 U.S. 312 (1921)
While reasonable classification is permitted, without doing violence to the equal protection of the laws, such classification must be based upon some real and substantial distinction, bearing a reasonable and just relation to the things in respect to which such classification is imposed; and classification cannot be arbitrarily made without any substantial basis.
Plaintiffs William Truax and his co-partner owned and operated a restaurant (collectively, "Truex"). Defendants Michael Corrigan and others worked for Truex as cooks and waiters (collectively, "Employees"). The Employees were members of defendant Bisbee Local No. 380, Cooks' And Waiters' Union ("Union"). A dispute arose over the terms and conditions of employment and the Union ordered the Employees to strike. Defendants began a plan to injure Truex's business by picketing and discouraging patronage of the restaurant. Truex then filed a complaint against defendants in Arizona state court seeking to enjoin defendants from picketing, displaying banners, and intimidating Truex's customers. Defendants filed a demurrer to the complaint, primarily on grounds that a state statute barred injunctive relief in employment-related disputes unless there was a threat to property or property rights. The trial court sustained the demurrer and dismissed the complaint. The state supreme court affirmed the trial court's judgment. Truex was granted a writ of certiorari.
Did the trial court err by dismissing Truex's complaint?
The Supreme Court of the United States reversed the judgment of the state supreme court and remanded the case for further proceedings. The court ruled that Truex was denied equal protection of the law. The state stature's prohibition against injunctive relief in certain employment disputes denied the equal protection of the laws when applied to defeat injunctive relief against concerted action by striking workers to injure the employer's business though tactics such as those used by the Employees and the Union. The Court observed that Truex's business and property rights were violated, and the violation would be unlawful if committed by anyone except the Employees. The injunctive remedy available to other litigants was withheld from Truex simply because the Employees worked for Truex, and such denial violated Truex's right to equal protection of the law.
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