United States v. Enmons

United States v. Enmons, 410 U.S. 396 (1973), is a landmark decision by the United States Supreme Court which determined that the federal Anti-Racketeering statute of 1934, commonly referred to as the Hobbs Act, does not extend to violent acts committed by unions when pursuing lawful union objectives.

This dispute originated during a labor strike involving members of the International Brotherhood of Electrical Workers (IBEW), who caused damage to utility infrastructure, including shooting rifles at transformers and sabotaging a substation. The union was demanding increased wages and improved benefits from Gulf States Utilities Company, now part of Entergy. The federal government brought charges under the Hobbs Act.

The Supreme Court concluded that since the Hobbs Act prohibits robbery or extortion that interferes with interstate commerce, it does not apply to violent conduct aimed at legitimate union goals such as securing higher compensation for bona fide services.

Case specifics

The defendants faced indictment under the Hobbs Act for employing violence to disrupt commerce and acquire property—specifically wages and benefits—through wrongful coercion and threats. The statute imposes penalties including fines up to $10,000 and imprisonment for up to twenty years against anyone who obstructs commercial activity by force or intimidation.

The Court recognized that threats or force are considered wrongful only when the claimant has no lawful entitlement to the property in question. Given that federal law permits unions to strike, the use of force to obtain wage increases and benefits did not constitute extortion under the Hobbs Act. Consequently, the charges were dismissed; however, such violent behavior remains subject to prosecution under other applicable state or federal statutes.

In Enmons, the critical distinction lies in the Hobbs Act’s prohibition of extortion rather than all unlawful conduct. Federal laws like the National Labor Relations Act safeguard collective bargaining and strike activities directed toward legitimate labor objectives, which are excluded from extortion definitions. Therefore, a fundamental element required for a Hobbs Act violation is missing in union disputes concerning wages and benefits.

Legislative and public response

Since the ruling in 1973, various legislative efforts led primarily by Republicans have sought to overturn United States v. Enmons. Notably, the Freedom from Union Violence Act (FUVA), initially introduced by Rep. Phil Crane as H.R. 1796 in 1995, was repeatedly reintroduced but failed to progress beyond committee stages.

The National Right to Work Foundation cites United States v. Enmons as an example of "extraordinary powers and immunities" granted to American labor unions, emphasizing that union-related violence is excluded from Hobbs Act prosecution, which targets obstruction of interstate commerce through robbery or extortion. Nevertheless, legal experts Cohen and Yellig clarify that this decision does not provide unions with blanket immunity for violent actions; such conduct remains prosecutable under other state and federal laws. They note that much debate centers on how extortion is defined within federal law and its boundaries.

A 2001 law review article authored by professor Julius Getman and former Secretary of Labor Ray Marshall examined evidence regarding union violence, concluding there is no substantial empirical support for claims of increasing strike-related violence. Their analysis highlighted that such assertions often rely on unreliable sources like media accounts and fail to differentiate between actual physical assaults and lesser forms such as intimidation or verbal threats.

See also

• Entergy Corp. v. Riverkeeper Inc.
• Entergy Louisiana, Inc. v. Louisiana Public Service Commission

External links

• Small Business and Entrepreneurship Council: Efforts to Reform the Union's Negative Reputation