Il6 HARVARD LAW REVIEW. advance which Is being made to make remedies more direct and effectual. Reference has already been made to Toledo, A. & N. M. Ry. Co. V. Pennsylvania Co.^ That case has since been cited with approval, and followed several times.^ The effect of the injunction in that case was to require the defendants to perform their duty under the third section of the Interstate Commerce Act. It was negative in form, and enjoined the defendants from refusing to offer and extend to the plaintiff company the same equal facilities for interchange of traffic on interstate business between the defend- ant companies and the plaintiff, as are enjoyed by other railway companies, and from refusing to receive from plaintiff company cars billed from points in one State to points in another State, which might be offered to the defendant companies by the com- plainant; and from refusing to deliver in like manner to the com- plainant cars which might be billed over its line from points in one State to points in another State. The case arose out of the refusal of the defendant companies to handle such cars for the plaintiff company, because certain of their employees had declared a boycott against the defendant companies. The injunction was granted upon the filing of the bill, and although negative in form, it was mandatory in effect, and is spoken of by Judge Ricks as a mandatory injunction. Upon the principle of this case, the employees of another railroad company, who had refused to perform their usual and customary duties, were required by a preliminary mandatory injunction to perform all of their regular and accustomed duties so long as they remained in the employ of the complainant company. The refusal of these employees to handle Pullman cars on its road, as it was bound by contract to haul them, had the effect to interrupt inter- state commerce and the transmission of the mails, and subjected the company to suits and great and irreparable damage.^ The flexibility, usefulness, and efficiency of this writ is shown by a recent case in Minnesota.* The complainant in that case was the trustee in a railroad mortgage, given to secure bonds to the amount of $5,000,000. The defendant had recovered a judgment 1 (1893), 54 Fed. Rep. 746. 2 See Farmers' Loan & Trust Co. v. Northern Pac. R. R. Co. (1894), 60 Fed. Rep. 803, 814 ; Southern Cal. Ry. Co. v. Rutherford (1894), 62 Fed. Rep. 796, 797. 8 Southern Cal. Ry. Co. v. Rutherford (1894), 62 Fed. Rep. 796.
- Central Trust Co. of New York v. Moran (1894), 56 Minn. 188; 57 N. W.
Rep. 471.
