A History of Trade Unionism in the United States

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Evans in 1888.^ In that case an injunction against a boycott was justified on the ground that the value of the complainant's physical property was being destroyed when the market was cut off. Here the expectancies based upon relations which customers and employes were U07 Mass. SSS (1871).
'5 Pa. Co. Ct. 163 (1888).
158 TRADE UNIONISM IN THE UNITED STATES thought of as giving value to the physical property, but they were not yet recognized as a distinct asset which in itself justifies the issua
...nce of injunctions.
This next step was taken in the Barr ^ case in New Jersey in 1893. Since then there have been frequent statements in labor injunction cases to the effect that both the expectancies based upon the merchant-function and the expectancies based upon the employer-function are property.
But the recognition of "probable expectancies" as property was not in itself sufficient to complete the chain of reasoning that justifies injunctions in labor disputes.
It is well established that no recovery can be had for losses due to the exercise by others of that which they have a lawful right to do.


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