Note and Comment

Inducing Breach of Agreement by Employees Not to Join a Labor Union, in Order to Compel Unionization of Plaintiff's Business - In Hitchnan Coal & Coke Compazy v. John Mitchell, et al., (Dec. 10, 1917), 38 Sup. Ct. 6s, the novel question was presented to the Supreme Court of the United States, as to whether or not members of a labor Union could be enjoined from conspiring to persuade, and persuading, without violence or show of violence, plaintiff's employees, not members of the Union,-and who were working for plaintiff not for a specified time, but under an agreement not to continue in plaintiff's employment if they joined the Union, this agreement being fully known to defendants,-secretly to agree to join the Union and continue working for plaintiff until enough had agreed to join, so that a strike could be called, and plaintiff be thereby forced to unionize its business of mining coal.