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Quinn v Leathem
''Quinn v Leathem'' () (UKHL 2 ), is a case on economic tort and is an important case historically for British labour law. It concerns the tort of "conspiracy to injure". The case was a significant departure from previous practices, and was reversed by the Trade Disputes Act 1906. However, the issue of secondary action was later restricted from the Employment Act 1980, and now the Trade Union and Labour Relations (Consolidation) Act 1992. The case was heavily controversial at the time, and generated a large amount of academic discussion, notably by Wesley Newcomb Hohfeld, which continued long after it was overturned.
==Facts==
A trade union called the Belfast Journeymen Butchers' and Assistants' Association had wanted to enforce a closed shop agreement against Leathem's butcher business in Lisburn. They approached one of his customers, Andrew Munce in Belfast, and told him that he should refuse to trade with Leathem unless Leathem only employed workers who joined the trade union. They said that if Munce did not do as they wished, they would call a strike among Munce's own workers. Munce had been buying Leathem's beef for 20 years, though there had been no written contract about it, and none of Munce's workers had yet been induced to strike (break their contracts).
Leathem suffered considerable loss to his business, and brought an action for conspiracy. Lord Justice FitzGibbon instructed the jury that the crucial question was whether the defendants' dominant motive had been to injure the plaintiff. The jury found for the plaintiff and awarded him £200 damages.
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