Missouri v. National Organization for Women, Inc.
United States Court of Appeals for the Eighth Circuit
620 F.2d 1301 (1980)
The National Organization for Women (NOW) (defendant) urged its members to boycott holding conventions in states, including Missouri (plaintiff), that had not ratified the proposed Equal Rights Amendment, hoping the economic pressure would push state legislatures to adopt it. Missouri sued NOW, claiming the boycott was a conspiracy to restrain trade under Sherman Act § 1; the district court ruled for NOW, finding the boycott protected under an exception for legitimate government-petitioning activity, and the court of appeals affirmed after Missouri's appeal.
Whether an economic boycott aimed at inducing non-economic legislative change is outside the scope of the Sherman Act, even if the boycott has incidental restraints on trade.