## Facts

- Journeymen shoemakers in Philadelphia organized the Federal Society of Journeymen Cordwainers to protect wages and regulate work conditions in a trade marked by recurring wage disputes and strikes.
- In 1805, the society pursued higher piece rates and a closed-shop approach by agreeing to work only at set rates and to stop work for any master who employed nonmembers or workers willing to accept lower rates.
- Employers asserted the society enforced its rules through internal discipline and collective pressure, including fines, organized shop visits by a “tramping committee,” and alleged intimidation of masters and noncomplying workers.
- The Commonwealth prosecuted eight society leaders, including George Pullis, on an indictment for common-law conspiracy, with prosecution costs and direction largely driven by master shoemakers.
- A jury drawn largely from property-owning tradesmen heard testimony describing wage-fixing agreements, coordinated “turn-outs” (strikes), and coercive incidents attributed to the society.

## Issues

1. Whether a combination of workers to raise and maintain wages constitutes a criminal conspiracy at common law, even if the combination relies primarily on a concerted refusal to work.
2. Whether alleged threats, menaces, fines, harassment, and closed-shop enforcement rendered the combination unlawful as a restraint on trade and interference with others’ ability to work.
3. Whether workers have a lawful right to combine for higher wages and improved conditions, comparable to employers’ collective efforts to protect their interests.

## Decision

- The court instructed the jury that it was settled at common law that combinations of workers to raise wages were unlawful.
- The jury found all defendants guilty of criminal conspiracy.
- Each defendant was fined $8 plus the costs of prosecution, which effectively bankrupted the society.
- No reported appeal followed; the judgment stood as the final disposition.

## Legal Principles

- Under prevailing common-law conspiracy doctrine, a concerted agreement by workers to raise wages and impose uniform labor terms could be treated as an unlawful combination restraining trade.
- The alleged unlawfulness was grounded in the collective nature and market effects of the agreement (wage control and coordinated work stoppage), not solely in violent or overtly coercive acts.
- Use of threats, menaces, organized intimidation, or internal sanctions to compel participation or exclude nonmembers strengthened the inference of an unlawful conspiracy.
- Courts could treat private worker “governance” mechanisms—discipline, enforcement committees, and coordinated withdrawals of labor—as improper interference with employers’ contracting choices and with nonmembers’ opportunity to work.

## Conclusion

The Philadelphia Mayor’s Court sustained criminal conspiracy convictions of journeymen shoemakers’ leaders for coordinating a wage-increase and closed-shop program, treating collective wage-setting and coordinated refusals to work—especially when backed by coercive enforcement—as unlawful restraints on trade subject to criminal punishment.


Commonwealth v. Pullis (Philadelphia Mayor’s Ct. 1806)