In the case of Coronado Coal Company et al. v. United Mine Workers of America et al., 1924, the U.S. Supreme Court ruled that labor unions could be held liable for damages caused by strikes they organized and supported, under the Sherman Antitrust Act. The dispute arose when a violent strike led by United Mine Workers against non-unionized mines in Arkansas resulted in significant property damage to Coronado Coal Company's facilities. The court found that because the union had conspired to restrain interstate commerce through their actions, it was subject to antitrust laws typically applied to businesses or corporations engaging in monopolistic practices or conspiracies restraining trade - even though its members were not directly engaged in such commerce themselves.

In the dissenting opinion for Coronado Coal Company v. United Mine Workers of America, Justice Oliver Wendell Holmes Jr., joined by Justices Brandeis and Stone, argued that the majority's decision to hold a labor union liable for damages caused during a strike was incorrect. He contended that strikes are lawful acts and unions should not be held responsible for any violence or destruction resulting from them unless it can be proven they directly incited such actions. Furthermore, he disagreed with the majority's interpretation of antitrust laws in this context; these laws were designed to prevent monopolies and promote competition rather than regulate labor disputes. The dissent also expressed concern about potential chilling effects on future union activities due to fear of legal repercussions if their members engage in unlawful conduct during strikes.