Buck's Stove Case: Gompers, Mitchell, Morrison Sentenced for Contempt, Boycotts Criminalized

A federal court sentenced AFL President Samuel Gompers to one year in prison, Vice President John Mitchell to nine months, and Secretary Frank Morrison to six months for contempt of court in the Buck’s Stove and Range Company boycott case. The case exemplified how federal courts had become instruments of corporate power, criminalizing fundamental labor organizing tactics through creative application of antitrust law and injunctions.

The Buck’s Stove company had refused to negotiate with the AFL over a nine-hour workday demand. The AFL placed the company on its “We Don’t Patronize” list and publicized the boycott through its publications. In 1907, the company obtained an injunction prohibiting not only the boycott but any publication of the dispute. When the AFL defied what it considered an unconstitutional restriction on speech, the court found Gompers and the other leaders in contempt.

Though the sentences were eventually vacated on technical grounds after years of appeals, the case demonstrated that federal courts would use injunctions and contempt powers to suppress labor organizing. The pattern established in Buck’s Stove and the Danbury Hatters case (Loewe v. Lawlor, 1908) made clear that boycotts, sympathy strikes, and even discussing labor disputes could be criminalized as restraints of trade. These judicial attacks on labor continued until the Norris-LaGuardia Act of 1932 limited labor injunctions. The case shows the depth of judicial capture during the Progressive Era, with courts functioning as a reliable ally of corporate interests against workers even as Progressive reformers achieved victories in other arenas.