## Facts

- Hunt and partners operated a motor-trucking business for about fourteen years, hauling freight largely in interstate commerce under contracts in the Philadelphia area.
- A local truck drivers’ union and its officers sought a closed shop for contract haulers serving major shippers.
- In 1937 the union struck to enforce a closed shop; Hunt’s partnership attempted to operate during the strike, which involved violence and a homicide for which a partner was tried and acquitted.
- After a closed shop agreement was reached, contract haulers were told their employees had to join the union.
- The union refused to negotiate with Hunt’s partnership and declined to admit any of its employees to union membership, while other haulers either joined or made closed shop arrangements.
- At the union’s urging, a shipper cancelled Hunt’s hauling contract to comply with its closed shop obligations; later, another hauling contract was lost after that company also entered a closed shop agreement.
- Because the union would not admit the partnership’s employees and union members would not work for the partnership, the partnership could not obtain additional hauling contracts in Philadelphia and its business was effectively destroyed.
- The elimination of the partnership’s services did not disrupt the interstate operations of the shippers served.
- The partnership sued in federal court seeking an injunction and treble damages under the Sherman Act, alleging the union’s conduct was motivated by hostility and unlawfully restrained trade.

## Issues

1. Whether a union violates the Sherman Act by refusing to admit an employer’s employees to membership and by members collectively refusing to work for that employer, when the result is to drive the employer out of business in interstate commerce.
2. Whether personal hostility motivating the union’s refusal converts otherwise lawful labor activity into an antitrust violation.
3. Whether the employer’s involvement in interstate commerce, without more, makes the union’s conduct actionable under the Sherman Act.

## Decision

- The Supreme Court affirmed judgment for the union.
- The Court held that the union’s refusal to admit the employer’s employees and members’ refusal to accept employment, even if it made it impossible for the employer to continue in business, did not violate the Sherman Act.
- The Court held that alleged personal antagonism did not transform the refusal into a Sherman Act offense.
- The Court rejected the view that a connection to interstate commerce alone supplies a Sherman Act remedy for the employer’s injury.

## Legal Principles

- A union’s and its members’ decision to withhold labor from a particular employer, and to decline to admit that employer’s employees to membership, is not a Sherman Act restraint of trade absent more.
- Personal hostility or allegedly wrongful motive does not, by itself, convert labor’s refusal to deal into an antitrust violation.
- The Sherman Act does not provide a remedy for every tort or business injury affecting participants in interstate commerce.
- Antitrust liability is not established where the conduct is not shown to involve a combination of labor with non-labor groups to restrain trade.
- A union’s alleged breach of representational or related duties to employees is not, standing alone, a Sherman Act violation.

## Conclusion

The Court treated the union’s conduct as a labor refusal to deal—declining membership and declining to work—rather than an anticompetitive market restraint, and held that neither the employer’s resulting business failure nor the alleged hostile motive created Sherman Act liability without proof of a trade-restraining combination or comparable antitrust wrong.


Hunt v. Crumboch, 325 U.S. 821 (1945)