Another famous decision of the Supreme Court growing out of the railway strikes of the early nineties was in the Lennon case[43] in 1897. Therein the court held that all persons who have actual notice of the issuance of an injunction are bound to obey its terms, whether they were mentioned by name or not; in other words, the courts had evolved the "blanket injunction."
At the end of the nineties, the labor movement, enriched on the one side by the lessons of the past and by the possession of a concrete goal in the trade agreement, but pressed on the other side by a new form of legal attack and by the growing consolidation of industry, started upon a career of new power but faced at the same time new difficulties.
[31] Springhead Spinning Co. v. Riley, L.R. 6 E. 551 (1868).
[32] Johnson Harvester Co. v. Meinhardt, 60 How. Pr. 171.
[33] Chicago, Burlington, etc., R.R. Co. v. Union Pacific R.R. Co., U.S. Dist. Ct., D. Neb. (1888).
[34] In re Debs, 158 U.S. 564 (1895).
[35] 107 Mass. 555 (1871).