In the second case referred to in the preceding paragraph the United States Supreme Court thus laid down the rule as to the "secondary boycott": It is to be observed that this [the case in hand] is not the mere case of a peaceful secondary boycott, as to the illegality of which courts have differed and States have adopted different statutory provisions. A secondary boycott of this kind is where many combine to injure one in his business by coercing persons against their will to cease patronizing him by threats of similar injury. In such a case the many have a legal right to withdraw their trade from the one, they have the legal right to withdraw their trade from third persons and they have the right to advise third persons of their intention to do so when each act is considered singly. The question in such cases is whether the moral coercion exercised over a stranger to the original controversy by steps in themselves legal becomes a legal wrong. But here the illegality of the means used is without doubt and fundamental. The means used are the libelous and abusive attacks on the plaintiffs' reputation, like attacks on their employers and customers. Threats of such attacks on would-be customers, picketing and patrolling of the entrance to their place of business and the consequent obstruction of free access thereto--all had the purpose of depriving the plaintiffs of their business. To give operation to a statute whereby serious losses inflicted by such unlawful means are in effect made remedyless, is, we think, to disregard fundamental rights of liberty and property and to deprive the person suffering the loss of due process of law."
It is with deepest regret that an announcement in our obituary columns in this issue includes the name of ex-Justice Bennet Van Syckel as a deceased member of the Bar and jurist. Those who practiced under him in the Circuits in former years, or who knew him as the bright, fully-equipped ornament of the Supreme Bench, well understand that his passing cuts off the last link between the Supreme Court of a few decades ago and the Court as constituted to-day. Justice Van Syckel was approaching 92 years of age, and many were the hopes that he would retain his health and vigor of intellect until he reached an even hundred years. The Courts wherein he sat, and the present older members of the Bar will see to it that his merits are officially pronounced; we can only say now that no eulogy to be given to his memory will do him over-justice. His dignity, fairness and sound legal judgment on the Bench were such that he deserved even greater honors than he received and his private life was immaculate. An excellent portrait of the Justice as he appeared in 1905 will be found in the Law Journal of that year (Vol. 28, facing p. 6).