## Facts

- A.A. Cross Construction Company, a nonunion contractor, worked on a construction project near Port Arthur, Texas, using nonunion workers alongside some union workers.
- A protest against the company’s hiring practices was organized by union-related entities.
- During the protest, company employees were assaulted, and construction equipment was burned and destroyed.
- The disruption delayed the project and contributed to Cross’s default on its contract.
- Cross and several employees alleged union members conspired to use violence to force nonunion workers to quit or join the union, targeting them due to their nonunion status.

## Issues

1. Whether a purely private conspiracy to infringe First Amendment rights violates 42 U.S.C. § 1985(3) without proof of state involvement or an aim to influence state activity.
2. Whether nonunion workers constitute a protected “class” under § 1985(3), and whether anti-nonunion (economic) bias satisfies the statute’s “class-based, invidiously discriminatory animus” requirement.

## Decision

- The Supreme Court reversed the § 1985(3) judgment against the unions.
- A § 1985(3) claim predicated on interference with First Amendment rights requires proof that the State was involved in the conspiracy or that the conspiracy aimed to influence state action.
- The asserted hostility toward nonunion workers did not satisfy § 1985(3)’s requirement of class-based, invidiously discriminatory animus.

## Legal Principles

- § 1985(3) does not federalize private interference with rights that are, by their nature, protections against government action (including First Amendment rights) absent state involvement or a purpose to affect governmental activity.
- To proceed under § 1985(3), a plaintiff must show class-based, invidiously discriminatory animus; economic or commercial hostility toward nonunion workers is insufficient.
- Violent conduct in labor disputes may be addressed through state-law remedies and other applicable statutes, but § 1985(3) is not a general federal tort remedy for privately motivated conspiratorial wrongdoing.

## Conclusion

The Court limited § 1985(3) by holding that private conspiracies aimed at First Amendment interests require a state nexus, and that anti-nonunion bias does not constitute the type of class-based, invidiously discriminatory animus needed to impose § 1985(3) liability.


United Bhd. of Carpenters & Joiners of Am., Loc. 610 v. Scott, 463 U.S. 825 (1983)