Interborough Rapid Transit Co. v. Lavin
The Interborough Rapid Transit Company sought an injunction against former employees who instigated a strike and were encouraging current employees to leave the company's established "Brotherhood" union to join the "Amalgamated Association." The case examined the legality of such inducement and the broad injunction initially granted pendente lite. The court found that while employees have the right to leave employment and join other unions, and outsiders can persuade them using lawful means, the injunction's broad scope was not justified. It reversed the prior orders and remitted the motion, questioning but not definitively ruling on whether urging employees to conceal their new union affiliations from their employer constitutes an unlawful means. The decision reaffirms that unlawful actions like trespass, force, or deceit can always be enjoined.