Supreme Court Invalidates Arizona Anti-Injunction Law in Truax v. Corrigan

The Supreme Court rules 5-4 in Truax v. Corrigan that an Arizona law prohibiting state courts from issuing injunctions against peaceful labor picketing violates the Due Process Clause of the Fourteenth Amendment. Chief Justice William Howard Taft, writing for the majority, holds that the Arizona statute deprives the restaurant owner of property rights without due process by allowing picketers to inflict economic harm without legal remedy. The case involves the English Kitchen restaurant in Bisbee, Arizona, where former employees picketed with banners denouncing the owner as “unfair to organized labor,” causing business to decline more than 50 percent. Despite no violence occurring, the Court finds that preventing judicial relief from economic damage caused by picketing constitutes an unconstitutional taking of property.

The decision represents a significant setback for organized labor and state-level legislative efforts to protect workers’ rights to strike and picket. Arizona had passed its anti-injunction law in 1913 specifically to address judicial favoritism toward employers in labor disputes, as courts routinely ended strikes by issuing injunctions against workers. Justice Louis Brandeis, joined by Oliver Wendell Holmes in dissent, condemns the majority for applying different standards to labor and capital: when capitalists combine to control industries, the Court finds their restraints “reasonable,” but when workers refuse to cross picket lines for self-protection, the Court discovers unreasonable interference. No other state passes similar protective legislation after 1921 due to the precedent. Congress eventually responds with the Norris-La Guardia Anti-Injunction Act in 1932, though workers suffer a decade of unchecked judicial suppression in the interim.

The Truax decision exemplifies how the Supreme Court during the Lochner Era weaponizes substantive due process and “freedom of contract” doctrine to systematically invalidate labor protections while sanctioning corporate combinations. The case establishes that employers’ property rights trump workers’ organizing rights, embedding anti-labor bias into constitutional interpretation that persists through the 1920s and contributes to the erosion of union power during the decade’s corporate ascendancy.