Since the early 1900s, when John R. Commons first assembled most of them in one place, the early republic's labor conspiracy cases have attracted considerable attention from both labor and legal historians.1 In the main – and notwithstanding that very different theoretical, political, and moral stances have been embraced by different protagonists – the question of labor conspiracy has generally been approached on a relatively narrow front and with more than half an eye on the course of industrial relations after the Civil War, the cases treated as of lasting significance primarily for what they reveal about the evolution of the law's role and priorities in conflicts between labor and capital. Within these parameters commentators have debated the reasons for the courts’ attribution of illegality to journeymen's combinations in the early nineteenth century, usually treating as the fundamental issue the question whether illegality is to be explained as the outcome of the application of normal processes of judicial reasoning to prevailing doctrine, or whether it is instead to be held up as a particularly egregious example of outright pro-employer bias and hostility to labor on the part of the judiciary.