H. R. Brown & Son v. United Mine Workers of America

25 Ohio N.P. (n.s.) 485
CourtTuscarawas County Court of Common Pleas
DecidedJuly 15, 1925
StatusPublished

This text of 25 Ohio N.P. (n.s.) 485 (H. R. Brown & Son v. United Mine Workers of America) is published on Counsel Stack Legal Research, covering Tuscarawas County Court of Common Pleas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
H. R. Brown & Son v. United Mine Workers of America, 25 Ohio N.P. (n.s.) 485 (Ohio Super. Ct. 1925).

Opinion

Reid, J.

The court in reaching its conclusion will not again call attention to the allegations of the petition, but will proceed at once with its reasons for the conclusion reached.

In this application for a temporary injunction we are called upon to determine the rights of the defendants under the facts presented by the evidence measured by the law applicable in such cases.

The right of labor unions to engage in the practice commonly called “picketing” and to indulge in the■ persuasion of non-union employees to leave their employment is involved to some extent. We think the evidence is undisputed that the difficulties involved in this controversy do not constitute what is commonly known as a “strike.” The plaintiff some years ago employed union labor in the operation of coal mines, but never in operating the mines in question in this ease. Por a period of perhaps two or three years they have operated in a small way on the open shop basis. The trouble seems to have culminated on their acquisition of a new property, which it was proposed to operate with non-union labor. The defendants regardless of the non-existence of any relation as employer and employee with union members, claim the right to exercise the privileges which the law gives them where members of a union are engaged in a “lawful strike.”

In the case of Park v. Hotel Employees, 22nd N. P., new series, page 257, in an opinion rendered by Judge Foran in 1919, a very exhaustive review is made of the question, which we think is involved in this controversy. Judge Foran was one of the ablest jurists of Cuyahoga county. On page 274 he gives a definition of a strike. This was a case considered ■by him in which the labor union sustained no working relation with the employer, but were seeking to compel recognition by the restaurant involved in the controversy, and was engaged in picketing and resorted to methods held legal under a lawful strike. After giving definitions from the various text [487]*487books and other legal authorities upon what a “strike” is, Judge Foran used the following language:

“It will be noticed in all these definitions, and in every definition of a strike that can be obtained, that a strike only results where there is the relation of employer and employee; that is, a strike can only be said to exist where there is a trade dispute between the employer and his workmen. This relation is the essential basis of the local right to maintain and enforce a strike. ' A strike can not be said to exist where the relation of employer and employees did not exist. Suppose, for instance, a labor union, says to a man who employs only non-union labor, “You discharge your men or compel them to join our union,” and if he refuses, they proceed to picket his factory, store or place of business and resort to the usual coercive tactics accompanying such picketing. The action of the union is not a strike, but is a boycott. Neither the union oí its members has any trade or other relations with the man, no dispute with him, except a dispute created by themselves. ’ ’

Judge Foran in this opinion gave an exhaustive review of all phases of the law and goes on to say, that it is perfectly proper for the members of a labor union themselves to advise their own members not to work, so far as the membership of the union is concerned. It does not assume the illegal aspect of a conspiracy to injure the person so long as the withdrawal of support is confined to their own members. If, however, union labor or other recognized organizations influence others not members of the organization, and the public generally not to trade with or have business relations with the person against whom the boycott is directed, then the boycott becomes an illegal conspiracy and will be enjoined.

I will call your attention to a more recent opinion of the Supreme Court by Florence Allen, in the 108th O. S., page 61, in the case of LaFrance Electrical Supply Company v. Brotherhood of Electrical Workers No. 8. At the termination of a contract with the union employees, the employer stated that .he was going to operate on a different basis of employment ..and solicited the union members, who had been working for him to sign individual contracts which permitted him to .employ union, as well as non-union labor. The employer set up [488]*488the claim that the relation of employer and employee did not exist, the contract having terminated, and that he should, therefore, be permitted to enter into this method, which was legal, and that no trade dispute existed, and that for this reason picketing was illegal. The lower courts, and also,the Supreme Court, held in this case that a trade dispute did exist and that while technically the contract of employment had terminated, that, inasmuch as, the employers solicited the members of the union who had been in their employ before, and many of them had signed individual contracts to continue work, that a trade dispute did exist.

In our opinion the court by very strong inference points out the conditions where picketing and persuasion may be employed, and that these are limited to a strike growing out of a legitimate trade dispute. The court speaking with approval of the decisions of other courts, at page 84 of the opinion uses this language:

“A long line of authority in the lower tribunals, which includes decisions of outstanding judges in the nisi prius courts in this state, hold that in the prosecution of a strike, that is, a refusal of employees to work owing to a legitimate trade dispute with their employers, workingmen may legally place pickets or patrols within a reasonable distance of the employer’s place of business for the purpose of observing the progress of the strike. These decisions have been acquiesced in in this state for almost twenty-five years, the period during which industrial strife has become most prominent. It is also generally held by the same Ohio lower courts that striking workmen may peacefully persuade men and women still working under their former employer to abstain from working for the employer during the continuance of such strike, and may peaceably persuade new workmen not to accept employment.”

It seems clear that the courts have never extended this extraordinary privilege to workmen to engage in picketing only in case of what is termed a “lawful strike.”

The writing admitted in evidence, which was signed some years ago by plaintiffs will not alter these rules. Whatever moral obligation this promise to never employ non-union labor, [489]*489may impose would not give it the force of a trade dispute. It covers no specific period of time and it probably violates the Valentine anti-trust law of the state; and if so is made void by statute. It has not been regarded or followed for several years. If a liability to the defendants ever accrued on account of this writing it would have to be enforced through legal proceedings and not by the methods employed under the circumstances in this ease."

If we are correct in our interpretations of the law, then these defendants were without right to engage in the picketing or persuasion of the employees to stop work for the purpose of injuring the plaintiff’s business, or compelling them to employ union labor. But if it be conceded that the defendants have all the rights that a legitimate trade dispute gives them, then what is their situation under the facts of this case ?

Referring to' the recent decision on the LaPranee ease 108th O. S., and reading from the bottom of page 86:—

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25 Ohio N.P. (n.s.) 485, Counsel Stack Legal Research, https://law.counselstack.com/opinion/h-r-brown-son-v-united-mine-workers-of-america-ohctcompltuscar-1925.