# In re Debs (1895) **Argued:** March 25–26, 1895 · **Decided:** May 27, 1895 · **Unanimous, Justice David Brewer** · 158 U.S. 564 The case that made the federal injunction the government's primary weapon against strikes — and the reason the [[Sherman Antitrust Act]]'s first decade reads as labor law rather than antitrust law. ## How it started as an antitrust case On July 2, 1894, during the [[Pullman Strike]], the U.S. attorney in Chicago filed a complaint alleging that [[Eugene V. Debs]] and the officers of the American Railway Union had conspired to obstruct the mails **and to violate the Sherman Act**. Judge William A. Woods issued the injunction on that reasoning, holding that §1's phrase "combination in the form of trust **or otherwise**" was written broadly enough to reach labor unions — "the word 'otherwise' would not have been inserted by Congress" if it meant only capital. Debs was sentenced to six months for contempt on December 14, 1894; other officers got three. ## What the Supreme Court actually held Brewer affirmed — and then declined to rest on the statute at all. He chose what he called "broader ground": the federal government possesses an **inherent** equitable power to enjoin obstruction of interstate commerce and the mails, arising from its sovereignty over both, independent of any act of Congress. Because the power was equitable, violation could be punished as contempt without a jury. > "The strong arm of the national government may be put forth to brush away all obstructions to the freedom of interstate commerce or the transportation of the mails." ## Why it matters Brewer gave the executive branch something better than the Sherman Act: a tool that required no statute, no indictment, and no jury. For the next 37 years the labor injunction was the decisive fact of American strike law, until the **Norris-LaGuardia Act of 1932** stripped federal courts of jurisdiction to issue them in labor disputes. The through-line runs straight from here to [[Loewe v. Lawlor]] (1908), where the Court held the Sherman Act reaches unions directly and individual workers' homes were attached to satisfy the judgment. Congress answered with §6 of the [[Clayton Antitrust Act]] — "the labor of a human being is not a commodity or article of commerce." **The anti-monopoly statute's first sustained use was against organized labor, and it took 42 years to close that door.** Debs entered prison a union leader and left it a socialist; he read Marx in the Woodstock jail and ran for president five times. See [[US Antitrust and Monopoly Timeline]].