The U.S. Supreme Court case Savings Bank of Danbury v. Loewe (1916) revolved around the Sherman Antitrust Act and its application to labor unions. The plaintiff, D.E. Loewe & Company, a hat manufacturing firm in Connecticut, sued the United Hatters of North America and other defendants for damages under the Sherman Act after they organized a nationwide boycott against their products due to disputes over unionization efforts at their factory. The court ruled that such actions by labor unions constituted an illegal restraint on trade or commerce among several states as defined by the act - marking one of the first times it was applied to non-commercial organizations like labor unions - thereby affirming lower courts' decisions in favor of D.E.Loewe & Co., which had been awarded treble damages amounting to approximately $252,000.

In the dissenting opinion for Savings Bank of Danbury v. Loewe, Justice Holmes argued that the Sherman Act should not apply to labor unions because they are not typically considered "combinations" in the same sense as corporations or other business entities. He believed that applying this law to labor organizations could potentially infrive on workers' rights to organize and bargain collectively. Furthermore, he contended that a strike does not constitute an illegal restraint of trade under antitrust laws since it is fundamentally different from monopolistic practices employed by businesses. In his view, strikes are merely collective actions taken by workers seeking better working conditions or wages rather than attempts to control market competition unfairly.