## Facts

- Anheuser-Busch operated in St. Louis and used materials and products moving in interstate commerce; it also leased adjacent property to a tenant engaged in construction activity.
- A jurisdictional dispute existed between carpenters and machinists over which union’s members would perform work “erecting and dismantling machinery.”
- Anheuser-Busch had contracts allocating that work to machinists and requiring the carpenters’ union to arbitrate disputes.
- Union officers demanded that Anheuser-Busch reassign the disputed work to carpenters.
- After Anheuser-Busch refused, the carpenters’ union called a strike affecting firms working on the premises, picketed the property, and urged a consumer boycott of Anheuser-Busch beer.
- The United States alleged the union officers conspired, through strikes, picketing, and boycott activity, to restrain and monopolize interstate trade in violation of the Sherman Act.

## Issues

1. Whether union officials may be criminally prosecuted under the Sherman Act for strike, picketing, and boycott conduct affecting interstate commerce when the conduct occurs in a “labor dispute.”
2. Whether § 20 of the Clayton Act, read with the Norris-LaGuardia Act’s definition of “labor dispute,” immunizes such union conduct from Sherman Act criminal liability, including in a dispute between rival unions over work assignments.

## Decision

- The Supreme Court affirmed the district court’s judgment quashing the indictment.
- The Court held that, in assessing alleged antitrust violations by unions, the Sherman Act must be construed together with § 20 of the Clayton Act and the Norris-LaGuardia Act.
- The alleged conduct (strike, peaceful picketing, persuasion of others not to work, and a boycott recommendation) fell within the union activities protected by § 20, as informed by Norris-LaGuardia’s broad definition of “labor dispute.”
- Because § 20 declares the enumerated activities shall not be considered violations of federal law, those activities could not be punished as criminal violations under the Sherman Act.

## Legal Principles

- When trade-union conduct is alleged to violate antitrust law, the Sherman Act must be read in conjunction with § 20 of the Clayton Act and the Norris-LaGuardia Act.
- Union activities enumerated in § 20 (including strikes, peaceful picketing, and concerted refusals to work) are not “violations of any law of the United States” and are therefore not criminally punishable under the Sherman Act.
- The statutory protection is not limited to disputes solely between an employer and its employees; it extends to union conduct directed at an employer arising from a jurisdictional conflict between rival unions seeking the same work.
- Conduct does not lose § 20 protection merely because it affects interstate commerce or is directed in part at parties outside the immediate labor controversy, so long as it is part of a “labor dispute” as defined by Norris-LaGuardia.

## Conclusion

The Court held that core union pressure tactics alleged in the indictment—strike activity, picketing, and urging a boycott—occurred within a statutorily defined labor dispute and were insulated by Clayton Act § 20, as construed through Norris-LaGuardia, foreclosing criminal prosecution under the Sherman Act.


United States v. Hutcheson, 312 U.S. 219 (1941)