Gompers V. United States
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''Gompers v. United States'', 233 U.S. 604 (1914), was a
contempt of court Contempt of court, often referred to simply as "contempt", is the crime of being disobedient to or disrespectful toward a court of law and its officers in the form of behavior that opposes or defies the authority, justice, and dignity of the cour ...
case decided by the
Supreme Court of the United States The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
.


Background

Before 1932, the courts attempted to control the activities of labor unions by issuing injunctions that forbade strikes and picketing. Around the turn of the century labor unions began increasingly to use boycotts against individual employers to force them to provide improved working conditions and higher wages. The courts attempted to stop the boycotts by using antilabor injunctions. Samuel Gompers was the first president of the
American Federation of Labor The American Federation of Labor (A.F. of L.) was a national federation of labor unions in the United States that continues today as the AFL-CIO. It was founded in Columbus, Ohio, in 1886 by an alliance of craft unions eager to provide mutu ...
(AFL), holding the office from 1886 to 1924. Gompers and two other labor leaders were convicted of violating an antiboycott injunction for running a notice in its magazine listing Buck's Stove & Range Company along with other companies under the heading "We Don't Patronize." On May 25, 1911, the Supreme Court ruled on the case '' Gompers v. Buck's Stove & Range Company''.. The Court refused to reexamine the validity of the injunction issued by the lower court and rejected Gompers' claim that the First Amendment protected his activities. However, the convictions were reversed on the ground that the contempts were civil but the lower court had treated them as criminal in nature. The aim of civil contempt is remediation while the purpose of criminal contempt is punitive. Although the Court had dismissed the charges in ''Gompers v. Buck's Stove & Range Company'', the Supreme Court of the District of Columbia retained the power to punish contempt, if any had been committed against it. The day after the decision, this court appointed a committee to see if there was reasonable cause to believe that Gompers was guilty of willfully violating an injunction issued by the court on 18 December 1907. On June 26, 1911, the committee reported that Gompers was guilty of violating the injunction. Rules to show cause were issued that day requiring each of the defendants to show why they should not be adjudged to be in contempt and be punished for it. Gompers pleaded the statute of limitations and not guilty to most of the charges. A trial took place, the statute of limitations was held inapplicable, and Gompers was found guilty and sentenced to prison for 12 months. The court of appeals reduced the sentence to imprisonment for 30 days. Gompers appealed to the Supreme Court, arguing that the alleged contempt took place more than three years before the proceedings began and was therefore beyond the statute of limitations.


Decision

The Court reversed the decision of the lower court based on its holding that criminal contempt was a crime to which the statute of limitations applies.


Significance

The Court settled whether contempt was actually a crime by the affirmative. It also resolved the issue of a statute of limitations for punishing contempt, settling on a term of three years.


See also

* Gompers v. Buck's Stove & Range Co.


References


External links


Great Court Cases
* {{caselaw source , case = ''Gompers v. United States'', {{ussc, 233, 604, 1914, el=no , cornell = https://www.law.cornell.edu/supremecourt/text/233/604 , courtlistener = , findlaw = https://caselaw.findlaw.com/us-supreme-court/233/604.html , googlescholar = https://scholar.google.com/scholar_case?case=11918843173601231593 , justia = https://supreme.justia.com/cases/federal/us/233/604/ , loc =http://cdn.loc.gov/service/ll/usrep/usrep233/usrep233604/usrep233604.pdf United States Supreme Court cases United States Supreme Court cases of the White Court American Federation of Labor 1914 in United States case law Samuel Gompers