In re Debs

Federal Trials and Great Debates 

in United States History

Case Summary:

• In 1894, Eugene Debs’ American Railway Union boycotted Pullman railway cars in solidarity with 

striking workers at the Pullman Palace Car Co.

• Debs was sentenced to six months in prison for violating a federal court’s injunction prohibiting 

him from most forms of involvement in the strike.

• The Supreme Court upheld the conviction, outlining a broad power to restrict the activities of 

unions and their leaders. 

History of the Case:

The Pullman Palace Car Co. was the nation’s leading manufacturer of railroad passenger cars in the late 

nineteenth and early twentieth centuries. Following a national economic crisis in 1893, the company 

attempted to lower its employees’ wages, though it did not decrease the costs of living in company 

housing. Workers at the company went on strike in protest. The American Railway Union (“ARU”), a major 

labor organization headed by Eugene Debs, joined the strike in sympathy with the Pullman workers. 

Railway workers refused to couple Pullman cars to trains or to work on trains that used Pullman cars. At a 

time when much of the nation’s transport, commerce, and communication took place via the rails, this 

strike threatened to bring the national economy to a standstill.

Chicago was the epicenter of the strike. The governor of Illinois, eager to avoid the violence that 

had accompanied some other strikes, was initially reluctant to use the police to protect railway property. 

Moved by concerns about the national economic effects of the strike, however, President Grover 

Cleveland ordered troops to patrol railyards and prevent blockades of rail lines. The troops and protesters 

clashed violently at times.

At the same time, Cleveland’s administration sought to end the strike through the courts. 

Government attorneys successfully sought an injunction in the U.S. Circuit Court for the Northern District 

of Illinois against Debs and other union leaders, arguing that the strike was unlawfully interfering with mail

delivery and interstate commerce. Injunctions are court orders prohibiting individuals or groups from 

engaging in specified acts. The use of injunctions in labor strikes was relatively new at the time. Most 

injunctions had been confined to cases where the government had some property stake in a bankrupt 

railroad. The court’s order in this case was controversial because it effectively enabled the government to 

break up almost any strike on the theory that it interfered with commerce.

Believing the court’s order illegitimate, Debs continued to communicate with his union’s local 

branches regarding the strike, which spread and intensified after the court issued the injunction. In all, 30 

people died in violence between federal troops and workers. Debs was arrested for contempt of court and 

sentenced to six months’ imprisonment. He petitioned the Supreme Court of the United States for a writ of 

habeas corpus (a mechanism for challenging the legality of a detention). Debs argued the lower court’s 

injunction exceeded its legal authority. Ordinarily, his lawyers pointed out, injunctions were only issued to 

protect some property interest from being damaged by another (an order preventing someone from 

pulling down an individual’s house, for example). By contrast, Debs argued the government was not 

protecting any legitimate property rights of its own; it was intervening on behalf of wealthy corporations in 

a dispute with their workers. Debs’ lawyers also argued that the imposition of a jail term for the contempt 

charge violated Debs’ right to a trial by jury.

The circuit court based its power to issue the injunction on the Sherman Anti-Trust Act of 1890. 

This law had been designed to break up large, monopolistic corporations. Even so, it used broad 
language prohibiting “combinations” that restrained interstate trade. The Supreme Court based its 

decision in Debs on even broader grounds. In an opinion written by Justice David Brewer, the Court held 

that the government had a property interest in the mail. Moreover, the Court stated, since the government 

had the power to regulate interstate commerce, it had the authority to request a federal court to issue an 

injunction against anyone interfering with that power. 

The Court also rejected Debs’ argument that the contempt conviction violated his right to a jury. 

The circuit court, Brewer explained, had exercised its equity powers in issuing the injunction. Equity is a 

distinct branch of the law that uses remedies, like injunctions, that are designed to be flexible and are 

adjudicated by a judge sitting without a jury. The power to issue injunctions, Brewer reasoned, implied the 

power to punish individuals who defied them. It would rob the proceedings of their efficiency and flexibility 

to require a jury to give effect to the injunction.

Taken to its logical conclusion, the Supreme Court’s rationale would have given judges a 

remarkably broad power to enjoin strikes and, indeed, federal courts issued thousands of strike-busting

injunctions in the years following Debs. Activists sympathetic to the labor cause lambasted the idea of 

“government by injunction” and criticized the courts as partisan actors in the great economic issues of the 

day. In 1932, Congress passed the Norris-LaGuardia Act, which contained a provision designed by future 

Supreme Court Justice Felix Frankfurter to prohibit courts from issuing injunctions against strikes. 

Subsequent legislation granted workers the right to bargain collectively with their employers. 

The ARU collapsed soon after the Debs decision, but Debs himself continued to be a prominent 

figure in the labor and socialist movements following his imprisonment. He was again the focus of a major 

Supreme Court case when he was sentenced to ten years in prison during World War I for making antiwar speeches. The Court upheld Debs’ sentence in 1919, though President Warren G. Harding pardoned 

him in 1921. Debs ran for president as a socialist candidate several times, receiving approximately 3% of 

the vote from his prison cell in the 1920 election. 

Legal Issues:

• Did the government have the authority to seek an injunction from the circuit court breaking up the 

Pullman strike?

• Did the circuit court’s punishment of Debs for contempt of court violate his right to a jury trial?

• Did Debs and his colleagues violate federal anti-trust laws by boycotting Pullman cars?

Questions for Discussion:

• At the time of the Debs case, the conflict between organized labor and the proprietors of large 

corporations was one of the nation’s most prominent political issues. Why might the resolution of 

strikes through orders issued by unelected judges prove controversial in this context?

• Both large corporations and national labor unions were relatively new entities in the 1890s. What 

special challenges might such organizations pose to a legal system used to resolving disputes 

between individuals and smaller companies? 

• At the time Debs was decided, many reformers argued that the federal courts were “on the side” 

of large corporations. How might the rulings in this case support or contradict that critique?