[30]
But the significance of the eighties in the development of relations of
the courts to organized labor came not from these cases which were,
after all, nothing but ordinary police cases magnified to an unusual
degree by the intensity of the industrial struggle and by the excited
state of public opinion, but in the new lease of life to the doctrine of
conspiracy as affecting labor disputes. During the eighties and nineties
there seemed to have been more conspiracy cases than during all the rest
of the century. It was especially in 1886 and 1887 that organized labor
found court interference a factor. At this time, as we saw, there was
also passed voluminous state legislation strengthening the application
of the common law doctrine of conspiracy to labor disputes. The
conviction of the New York boycotters in 1886 and many similar
convictions, though less widely known, of participants in strikes and
boycotts were obtained upon this ground.
Where the eighties witnessed a revolution was in a totally new use made
of the doctrine of conspiracy by the courts when they began to issue
injunctions in labor cases.
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