In Gompers v. United States (1913), the U.S. Supreme Court ruled on a case involving contempt of court and labor rights. Samuel Gompers, president of the American Federation of Labor, was found guilty by lower courts for violating an injunction against promoting a boycott during a labor dispute with Buck's Stove & Range Company. The Supreme Court overturned this decision, ruling that Gompers and his associates were not in criminal contempt because they had not disobeyed any clear or specific order from the court but rather violated an overly broad injunction which did not specify what actions would constitute disobedience to it. This case is significant as it established limits on how broadly courts could write their orders in such cases and protected union activities like boycotting under certain circumstances.

In the dissenting opinion for Gompers v. United States, Justice Holmes argued that the court had overstepped its bounds by punishing contempt of court as a crime rather than as a civil matter. He believed that this was an abuse of power and violated the defendants' rights to due process under law. Furthermore, he contended that it is not within the jurisdiction of courts to punish individuals for actions outside their immediate purview or control, such as publishing articles in newspapers - which was one of the acts deemed contemptuous in this case. The justice also expressed concern about potential misuse and misinterpretation of 'contempt powers', cautioning against turning them into instruments for suppressing freedom of speech or expression.