# Loewe v. Lawlor (1908) **Decided:** February 3, 1908 · Chief Justice Melville Fuller · unanimous Held that the [[Sherman Antitrust Act]] reaches **labor unions**, and that the United Hatters' nationwide secondary boycott of D.E. Loewe & Company's hats was a "combination in restraint of trade." The consequences were not abstract. A 1909 jury awarded $74,000, trebled to $222,000; *Lawlor v. Loewe* (1915) affirmed that the judgment could be satisfied against **individual union members' homes and bank accounts**, and the matter settled in 1917 for roughly $234,000. Hatters in Danbury, Connecticut lost their houses to an antitrust judgment. Together with the Pullman injunction and *In re Debs* (1895), this is the evidence for the most uncomfortable fact in the American antitrust record: **the first sustained use of the anti-monopoly statute was against organized labor, not against the trusts.** Congress responded with §6 of the [[Clayton Antitrust Act]] in 1914 — "the labor of a human being is not a commodity or article of commerce" — which the Court then read narrowly in *Duplex Printing* (1921) until the Norris-LaGuardia Act of 1932. > Stub — fill out. See [[US Antitrust and Monopoly Timeline]].