Wednesday, November 13, 2013

Amalgamated Food Employees Union Local 590 v. Logan Valley Plaza, Inc. case brief

Amalgamated Food Employees Union Local 590 v. Logan Valley Plaza, Inc. case brief summary
391 U.S. 308 (1968)


CASE SYNOPSIS
Petitioners sought review of a decision of the Supreme Court of Pennsylvania that affirmed the issuance of an injunction precluding petitioners from picketing on respondents' property on the sole ground that petitioners' conduct constituted a trespass on respondents' property.

CASE FACTS
Petitioners were union members picketing respondents' employment practices. The business was located in a shopping center. Respondents obtained an injunction issued by the trial court enjoining petitioners from picketing. On appeal, the state supreme court affirmed.

DISCUSSION
  • Again on appeal, the United States Supreme Court held that petitioners could not be enjoined under state trespass law from picketing on respondents' property; the injunction violated petitioners' rights under U.S. Constitutional Amendment I, XIV. 
  • The Supreme Court held that the shopping center was the functional equivalent of a business district. 
  • Because the shopping center served as a community business block and was freely accessible and open to the public, the state could not delegate the power, through the use of its trespass laws, wholly to exclude those members of the public wishing to exercise their First Amendment rights on the premises in a manner and for a purpose generally consonant with the use to which the property was actually put. 
  • Respondents' ownership of the property as the sole support of the injunction issued against petitioners was insufficient.

CONCLUSION
The Court reversed the decision.

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