Anderson v. Shipowners Ass'n of the Pac. Coast
In Anderson v. Shipowners Ass'n of the Pac. Coast, 272 U.S. 359, 71 L. Ed. 298, 47 S. Ct. 125 (1926), the Supreme Court held that a seaman, on behalf of himself and other members of the seamen's union, could sue an association of most of the shipowners in the region when the shipowners' association adopted unduly strict regulations governing employment. (272 U.S. at 359.)
The Court found the shipowners' agreement violated the antitrust laws because the regulations prevented the "free exercise of the rights" of the seamen to engage in trade and commerce. Id. at 363 (quoting United States v. Colgate & Co., 250 U.S. 300, 307, 63 L. Ed. 992, 39 S. Ct. 465 (1919)).
In Anderson v. Shipowners' Ass'n, 272 U. S. 359, 47 S. Ct. 125, 126, 71 L. Ed. 298 (1926), plaintiff sought to enjoin the shipowners' association whose men controlled substantially all the merchant vessels of American registry, who engaged in interstate and foreign commerce, because they had entered into an arrangement to control the employment of all seamen on their vessels by maintaining employment agents in California and where every seaman was compelled to register and await his turn in order to secure employment.
No person could secure employment unless he was registered, with the result that some seamen were delayed in securing work.
The plaintiff was barred from employment because of failure to comply with these regulations, and brought this suit asking for an injunction and damages.
In holding that the combination was illegal, the court said:
"If the restraint thus imposed had related to the carriage of goods in interstate and foreign commerce - that is to say, if each ship owner had precluded himself from making any contract of transportation directly with the shipper, and had put himself under an obligation to refuse to carry for any person without the previous approval of the associations - the unlawful restraint would be clear. But ships and those who operate them are instrumentalities of commerce, and within the commerce clause, no less than cargoes. It is not important, therefore, to inquire whether, as contended by respondents, the object of the combination was merely to regulate the employment of men, and not to restrain commerce. A restraint of interstate commerce cannot be justified by the fact that the object of the participants in the combination was to benefit themselves in a way which might have been unobjectionable, in the absence of such restraint. These shipowners and operators having thus put themselves into a situation of restraint upon their freedom to carry on interstate and foreign commerce according to their own choice and discretion, it follows, as the case now stands, that the combination is in violation of the Anti-Trust Act."