In the case of Eagle Glass & Manufacturing Company v. Rowe, 1917, the U.S. Supreme Court ruled in favor of the American Flint Glass Workers' Union and its president, Mr. Rowe. The dispute arose when Eagle Glass & Manufacturing Company accused the union of conspiring to restrain trade by enforcing a closed-shop agreement that required all employees to be members of their union as a condition for employment at glass factories across West Virginia. The company argued this was an illegal restraint on trade under federal antitrust laws (Sherman Act). However, the court disagreed with this argument stating that labor unions were not subject to these laws because they did not engage in commerce but rather sought better working conditions and wages for their members through collective bargaining agreements with employers.

The dissenting opinion in the case of Eagle Glass & Manufacturing Company v. Rowe, et al., argued that the majority's decision to uphold an injunction against a labor union for picketing was incorrect and infringed upon workers' rights. The dissent contended that peaceful picketing should be considered a lawful means by which workers can express their grievances and seek improvements in working conditions or wages. They believed it is not inherently coercive or harmful to business interests, but rather an essential part of collective bargaining process and freedom of speech. Furthermore, they disagreed with the majority's interpretation of "conspiracy," arguing that simply combining efforts for mutual aid does not constitute illegal conspiracy unless there are unlawful acts involved. Thus, they felt this ruling could potentially criminalize legitimate union activities.