Note J — Sherman Act Intended to Apply to Labor Unions

In the Debs case the Circuit Court based its decision almost entirely upon the Sherman Law. The Supreme Court of the United States, in affirming this decision, rested mainly on the broader question of the interference with the United States mails. Justice Brewer, however, who wrote the decision, specifically said that this fact did not mean that the Supreme Court dissented from the grounds on which the lower tribunal had decided the case.