of legal
theories on labor disputes, the issuance of injunctions was merely
sporadic, but a veritable crop came up during 1893-1894. Only the
best-known injunctions can be here noted. The injunctions issued in the
course of the Southwest railway strike in 1886 and the Burlington strike
in 1888 have already received mention. An injunction was also issued by
a Federal court during a miners' strike at Coeur d'Alene, Idaho, in
1892.[38] A famous injunction was the one of Judges Taft and Rickes in
1893, which directed the engineers, who were employed by connecting
railways, to handle the cars of the Ann Arbor and Michigan railway,
whose engineers were on strike.[39] This order elicited much criticism
because it came close to requiring men to work against their will. This
was followed by the injunction of Judge Jenkins in the Northern Pacific
case, which directly prohibited the quitting of work.[40] From this
injunction the defendants took an appeal, with the result that in Arthur
_v._ Oakes[41] it was once for all established that the quitting of work
may not be enjoined.

During the Pullman strike numerous injunctions, most sweeping in
character, were issued by the Federal courts upon the initiative of the
Department of Justice. Under the injunction which was issued in Chicago
arose the famous contempt case against Eugene V. Debs,[42] which was
carried to the Supreme Court of the United States. The decision of the
court in this case is notable, because it covered the main points of
doubt above mentioned and placed the use of injunctions in labor
disputes upon a firm legal basis.

Another famous decision of the Supreme Court growing out of the railway
strikes of the early nineties was in the Lennon case[43] in 1897.
Therein the court held that all persons who have actual notice of the
issuance of an injunction are bound to obey its terms, whether they were
mentioned by name or not; in other words, the courts had evolved the
"blanket injunction."

At the end of the nineties, the labor movement, enriched on the one side
by the lessons of the past and by the possession of a concrete goal in
the trade agreement, but pressed on the other side by a new form of
legal attack and by the growing consolidation of industry, started upon
a career of new power but faced at the same time new difficulties.

FOOTNOTES:

[29] See above, 6.

[30] See above, 91-93.

[31] Springhead Spinning Co. _v._ Riley, L.R. 6 E. 551 (1868).

[32]