Editing Taft–Hartley Act

{{short description|1947 U.S. federal law regulating labor unions}}
{{Infobox U.S. legislation
| name = Labor Management Relations Act, 1947
| fullname = An Act to amend the National Labor Relations Act, to provide additional facilities for the mediation of labor disputes affecting commerce, to equalize legal responsibilities of labor organizations and employers, and for other purposes.
| nickname = Taft–Hartley Act
| enacted by = 80th
| effective date = June 23, 1947
| public law url = 
| cite public law = {{USPL|80|101}}
| cite statutes at large = {{usstat|61|136}}
| acts amended = 
| title amended = [[Title 29 of the United States Code|29 U.S.C.: Labor]]
| sections created = {{Usc-title-chap|29|7}} §§ 141–197
| sections amended = 
| leghisturl = 
| introducedin = House
| introducedbill = {{USBill|80|H.R.|3020}}
| introducedby = [[Fred A. Hartley, Jr.]] ([[Republican Party (United States)|R]]–[[New Jersey|NJ]])
| introduceddate = April 10, 1947
| committees = 
| passedbody1 = House
| passeddate1 = April 17, 1947
| passedvote1 = [https://www.govtrack.us/congress/votes/80-1947/h27 308-107]
| passedbody2 = Senate
| passeddate2 = May 13, 1947
| passedvote2 = [https://www.govtrack.us/congress/votes/80-1947/s56 68-24], in lieu of {{USBill|80|S.|1126}}
| conferencedate = June 4, 1947
| passedbody3 = House
| passeddate3 = June 4, 1947
| passedvote3 = 320-79
| agreedbody3 = <!-- used when the other body agrees without going into committee -->
| agreeddate3 = <!-- used when the other body agrees without going into committee -->
| agreedvote3 = <!-- used when the other body agrees without going into committee -->
| agreedbody4 = <!-- used if agreedbody3 further amends legislation -->
| agreeddate4 = <!-- used if agreedbody3 further amends legislation -->
| agreedvote4 = <!-- used if agreedbody3 further amends legislation -->
| passedbody4 = Senate
| passeddate4 = June 6, 1947
| passedvote4 = 54-17
| signedpresident = 
| signeddate = 
| unsignedpresident = <!-- used when passed without presidential signing -->
| unsigneddate = <!-- used when passed without presidential signing -->
| vetoedpresident = [[Harry S. Truman]]
| vetoeddate = June 20, 1947
| overriddenbody1 = House
| overriddendate1 = June 20, 1947
| overriddenvote1 = [https://www.govtrack.us/congress/votes/80-1947/h49 331-83]
| overriddenbody2 = Senate
| overriddendate2 = June 23, 1947
| overriddenvote2 = [https://www.govtrack.us/congress/votes/80-1947/s86 68-25]
| amendments = [[Labor Management Reporting and Disclosure Act]]
| SCOTUS cases = {{ubl|''[[Garner v. Teamsters Union]]'', {{ussc|346|485|1953}}|''[[Construction Workers v. Laburnum Construction Corp.]]'', {{ussc|347|656|1954}}|''[[Weber v. Anheuser-Busch, Inc.]]'', {{ussc|348|468|1955}}|''[[Machinists v. Gonzales]]'', {{ussc|356|617|1958}}|''[[Linn v. United Plant Guard Workers]]'', {{ussc|383|53|1966}}|''[[Granite Rock Co. v. Teamsters]]'', {{ussc|561|287|2010}}|''[[Unite Here Local 355 v. Mulhall]]'', {{ussc|571|83|2013}}|''[[Starbucks Corporation v. McKinney]]'', {{ussc|docket=23-367|volume=602|year=2024}}}}
}}

The '''Labor Management Relations Act, 1947''', better known as the '''Taft–Hartley Act''', is a [[Law of the United States|United States federal law]] that restricts the activities and power of [[trade union|labor unions]]. It was enacted by the [[80th United States Congress]] over the [[veto]] of President [[Harry S. Truman]], becoming law on June 23, 1947.

Taft–Hartley was introduced in the aftermath of a major [[Strike wave of 1945–46|strike wave in 1945 and 1946]]. Though it was enacted by the [[Republican Party (United States)|Republican]]-controlled 80th Congress, the law received significant support from congressional [[Democratic Party (United States)|Democrats]], many of whom joined with their Republican colleagues in voting to override Truman's veto. The act continued to generate opposition after Truman left office, but it remains in effect.

The Taft–Hartley Act amended the 1935 [[National Labor Relations Act]] (NLRA), adding new restrictions on union actions and designating new union-specific [[unfair labor practice]]s. Among the practices prohibited by the Taft–Hartley act are [[jurisdictional strike]]s, [[wildcat strike action|wildcat strikes]], [[general strike|solidarity or political strikes]], [[secondary action|secondary boycotts]], secondary and mass [[Picketing (protest)|picketing]], [[closed shop]]s, and monetary donations by unions to federal political campaigns. The amendments also allowed states to enact [[right-to-work law]]s banning [[union shop]]s. Enacted during the early stages of the [[Cold War]], the law required union officers to sign non-communist affidavits with the government.

==Background==
{{See also|Strike wave of 1946|Presidency of Harry S. Truman}}

In 1945 and 1946, [[Strike wave of 1946|an unprecedented wave of major strikes]] affected the United States; by February 1946, nearly 2 million workers were engaged in strikes or other labor disputes. Organized labor had largely refrained from striking during [[World War II]], but with the end of the war, labor leaders were eager to share in the gains from a postwar economic resurgence.{{sfn|McCoy|1984|pp=49–51, 57}}

The [[1946 United States elections|1946 mid-term elections]] left [[Republican Party (United States)|Republicans]] in control of Congress for the first time since the early 1930s.{{sfn|McCoy|1984|pp=93–95}} Many of the newly elected congressmen were strongly conservative and sought to overturn or roll back [[New Deal]] legislation such as the [[National Labor Relations Act of 1935]], which had established the right of workers to join [[trade union|unions]], bargain collectively, and engage in strikes.<ref name="wagner1">{{cite web |last1=Wagner |first1=Steven |title=How Did the Taft-Hartley Act Come About? |url=https://historynewsnetwork.org/article/1036 |publisher=History News Network}}</ref> Republican senator [[Robert A. Taft]] and Republican congressman [[Fred A. Hartley Jr.]] each introduced measures to curtail the power of unions and prevent strikes. Taft's bill passed the Senate by a 68-to-24 majority, but some of its original provisions were removed by moderates, like Republican senator [[Wayne Morse]]. Meanwhile, the stronger Hartley bill garnered a 308-to-107 majority in the House of Representatives. The Taft–Hartley bill that emerged from a [[United States congressional conference committee|conference committee]] incorporated aspects from both the House and Senate bills.{{sfn|Bowen|2011|pp=49–51}} The bill was promoted by large business lobbies, including the [[National Association of Manufacturers]].<ref name="McCarthy"/>
[[File:David Dubinsky gives a speech against the Hartley-Taft bill, with Luigi Antonini in the audience, May 4, 1947. (5278798677).jpg|thumb|[[David Dubinsky]] of the [[International Ladies Garment Workers Union]] speaks against the Taft–Hartley Act, 4 May 1947]]
After spending several days considering how to respond to the bill, President Truman vetoed Taft–Hartley with a strong message to Congress,<ref>{{Cite web|url=https://millercenter.org/the-presidency/presidential-speeches/june-20-1947-veto-taft-hartley-bill|title=June 20, 1947: On the Veto of the Taft-Hartley Bill|date=2016-10-20|website=Miller Center|language=en|access-date=2019-02-22}}</ref> calling the act a "dangerous intrusion on [[Freedom of speech in the United States|free speech]]."<ref name=Nation/> Labor leaders, meanwhile, derided the act as a "slave-labor bill".<ref>{{cite news |url=http://www.time.com/time/magazine/article/0,9171,797962,00.html |archive-url=https://web.archive.org/web/20080416175321/http://www.time.com/time/magazine/article/0,9171,797962,00.html |url-status=dead |archive-date=April 16, 2008 |magazine=Time |title=National Affairs: Barrel No. 2 |date=June 23, 1947 |access-date=May 24, 2010}}</ref> Despite Truman's all-out effort to prevent a veto override, Congress overrode his veto with considerable Democratic support, including 106 out of 177 Democrats in the House, and 20 out of 42 Democrats in the Senate.<ref>Benjamin C. Waterhouise, [https://books.google.com/books?id=wYuGAAAAQBAJ&dq=taft+hartley+override+bipartisan&pg=PA53 ''Lobbying in America''], (Princeton University Press, 2013) 53.</ref><ref name=laborstory>{{cite book |last=Nicholson |first=Phillip |title=Labor's Story in the United States |publisher=Temple University Press |year=2004 |isbn=1-59213-239-1}}</ref>

==Effects of the act==
As stated in Section 1 ({{USC|29|141}}), the purpose of the NLRA is:
<blockquote>[T]o promote the full flow of commerce, to prescribe the legitimate rights of both employees and employers in their relations affecting commerce, to provide orderly and peaceful procedures for preventing the interference by either with the legitimate rights of the other, to protect the rights of individual employees in their relations with labor organizations whose activities affect commerce, to define and proscribe practices on the part of labor and management which affect commerce and are inimical to the general welfare, and to protect the rights of the public in connection with labor disputes affecting commerce.</blockquote>

The amendments enacted in Taft–Hartley added a list of prohibited actions, or [[unfair labor practice]]s, on the part of unions to the NLRA, which had previously only prohibited unfair labor practices committed by employers. The Taft–Hartley Act prohibited [[jurisdictional strike]]s, [[wildcat strike action|wildcat strikes]], [[general strike|solidarity or political strikes]], [[solidarity action|secondary boycotts]], secondary and mass [[Picketing (protest)|picketing]], [[closed shop]]s, and monetary donations by unions to federal political campaigns. It also required union officers to sign non-communist affidavits with the government. [[Union shop]]s were heavily restricted, and states were allowed to pass [[right-to-work law]]s that ban agency fees. Furthermore, the executive branch of the federal government could obtain legal strikebreaking [[injunction]]s if an impending or current strike imperiled the national health or safety.<ref>{{cite web|url=https://www.theatlantic.com/past/docs/issues/60feb/cox.htm |date=February 1960 |title=Strikes and the Public Interest – A Proposal for New Legislation |first=Archibald |last=Cox |work=The Atlantic}}</ref>

===Jurisdictional strikes===
In jurisdictional strikes, outlawed by Taft–Hartley, a union strikes in order to assign particular work to the employees it represents. Secondary boycotts and common situs picketing, also outlawed by the act, are actions in which unions picket, strike, or refuse to handle the goods of a business with which they have no primary dispute but which is associated with a targeted business.<ref>29 U.S.C. §§ 151–169 Section 8(b)(4)</ref>{{citation needed|date=February 2018}} A later statute, the [[Labor Management Reporting and Disclosure Act]], passed in 1959, tightened these restrictions on secondary boycotts still further.

===Campaign expenditures===
According to [[First Amendment to the United States Constitution|First Amendment]] scholar [[Floyd Abrams]], the act "was the first law barring unions and corporations from making independent expenditures in support of or [in] opposition to federal candidates".<ref name=Nation>[http://www.thenation.com/article/157720/debating-citizens-united Debating 'Citizens United'], ''[[The Nation]]'' (2011-01-13)</ref>

===Closed shops===
{{Main|Closed shop}}
The law outlawed closed shops which were contractual agreements that required an employer to hire only [[trade union|labor union]] members. Union shops, still permitted, require new recruits to join the union within a certain amount of time. The National Labor Relations Board and the courts have added other restrictions on the power of unions to enforce [[union security]] clauses and have required them to make extensive financial disclosures to all members as part of their [[duty of fair representation]].{{citation needed|date=March 2015}} On the other hand, Congress repealed the provisions requiring a vote by workers to authorize a union shop a few years after the passage of the act when it became apparent that workers were approving them in virtually every case.{{citation needed|date=March 2015}}

===Union security clauses===
{{Main|Union shop}}
The amendments also authorized individual states to outlaw union security clauses (such as the union shop) entirely in their jurisdictions by passing [[right-to-work law]]s. A right-to-work law, under Section 14B of Taft–Hartley, prevents unions from negotiating contracts or legally binding documents requiring companies to fire workers who refuse to join the union.{{citation needed|date=April 2015}} Currently all of the states in the [[Deep South]] and a number of states in the Midwest, Great Plains, and [[Rocky Mountains]] regions have right-to-work laws (with six states—[[Alabama]], [[Arizona]], [[Arkansas]], [[Florida]], [[Mississippi]], and [[Oklahoma]]—going one step further and enshrining right-to-work laws in their states' constitutions).{{citation needed|date=April 2015}}

===Strikes and lockouts===
====Notice provisions====
The amendments required unions and employers to give 80 days' notice to each other and to certain state and federal mediation bodies before they may undertake [[Strike action|strikes]] or other forms of economic action in pursuit of a new [[collective bargaining agreement]]; it did not, on the other hand, impose any "cooling-off period" after a contract expired. 

====National emergency provisions====
Section 206 of the Act, codified at 29 U.S.C. § 176, also authorized a president to intervene in strikes or [[lockout (industry)|lockouts]], under certain circumstances, by seeking a court order compelling companies and unions to attempt to continue to negotiate.<ref name=2023CRSEmergency>[https://crsreports.congress.gov/product/pdf/IF/IF12506 The UAW-Automakers Labor Dispute and Taft-Hartley's National Emergency Provisions], Congressional Research Service (October 2, 2023).</ref> Under this section, if the president determines that an actual or threatened lockout affects all or a substantial part of an industry engaged in interstate or foreign "trade, commerce, transportation, transmission, or communication" and that the occurrence or continuation of a strike or lockout would "imperil the national health or safety," the President may empanel a [[board of inquiry]] to review the issues and issue a report.<ref name=2023CRSEmergency/> Upon receiving the report, the president may direct the [[U.S. Attorney General]] to seek an injunction from a [[U.S. federal court|federal court]].<ref name=2023CRSEmergency/> If a court enters an [[injunction]], then a strike by workers or a lockout by employers is suspended for an 80-day period; employees must return to work while management and unions must "make every effort to adjust and settle their differences"<ref name=2023CRSEmergency/><ref name=Wiseman>Paul Wiseman, [https://apnews.com/article/port-strike-longshoremen-dockworkers-union-law-27c7eaa7b199fba1903a637eb6c7db0c The president could invoke a 1947 law to try to suspend the dockworkers' strike. Here's how], Associated Press (October 2, 2024).</ref> with the assistance of the [[Federal Mediation and Conciliation Service (United States)|Federal Mediation and Conciliation Service]].<ref name=2023CRSEmergency/> Presidents have invoked this provision 37 times.<ref name=Wiseman/> In 2002, President [[George W. Bush]] invoked the law in connection with the employer lockout of the [[International Longshore and Warehouse Union]] during negotiations with West Coast shipping and stevedoring companies.<ref name=Greenhouse>{{cite news|url=https://www.nytimes.com/2002/10/09/us/president-invokes-taft-hartley-act-to-open-29-ports.html?pagewanted=all |title=President Invokes Taft-Hartley Act To Open 29 Ports |first1=David E. |last1=Sanger |first2=Steven |last2=Greenhouse |newspaper=The New York Times |date=October 9, 2002}}</ref> This was the first successful invocation of the emergency provisions since President [[Richard M. Nixon]] intervened to halt a longshoremen's strike in 1971.<ref name=Greenhouse/>

====Prohibition on federal employee strikes====
Section 305 of the Act prohibited federal employees from striking.<ref name=Fleischli1968>{{cite journal |last=Fleischli|first=George R.|title=DUTY TO BARGAIN UNDER EXECUTIVE ORDER 10988|journal=Air Force Law Review|date=May–June 1968}}</ref> This prohibition was subsequently repealed and replaced by a similar provision, 5 U.S.C. § 7311, which bars any person who "participates in a strike, or asserts the right to strike against the Government of the United States" from federal employment.<ref>Kurt L. Hanslowe and John L. Acierno, [https://scholarship.law.cornell.edu/clr/vol67/iss6/2/ Law and Theory of Strikes by Government Employees], 67 Cornell L. Rev. 1055, 1059 n.16 (1982).</ref>

===Anti-communism===
{{main|McCarthyism}}
The amendments required union leaders to file affidavits with the [[United States Department of Labor]] declaring that they were not supporters of the [[Communist Party USA|Communist Party]] and had no relationship with any organization seeking the "overthrow of the United States government by force or by any illegal or unconstitutional means" as a condition to participating in NLRB proceedings. Just over a year after Taft–Hartley passed, 81,000 union officers from nearly 120 unions had filed the required affidavits.<ref name=laborstory/> This provision was at first upheld in the 1950 Supreme Court decision ''[[American Communications Ass'n v. Douds]]'', but in 1965, the Supreme Court held that this provision was an [[Constitutionality|unconstitutional]] [[bill of attainder]].<ref>{{cite court |litigants=United States v. Brown (1965) |vol=381|reporter=U.S. |opinion=437 |court=[[Supreme Court of the United States|Supreme Court]] |date=June 7, 1965|url=https://www.law.cornell.edu/supremecourt/text/381/437 |access-date=November 24, 2015 |quote=Held: Section 504 constitutes a bill of attainder and is therefore unconstitutional. }}</ref>

===Treatment of supervisors===
The amendments expressly excluded supervisors from coverage under the act, and allowed employers to terminate supervisors engaging in union activities or those not supporting the employer's stance.<ref name="nrhpinv1">{{cite web|url=http://www.politicalaffairs.net/taft-hartley-signed-60-years-ago/|title=Taft-Hartley Signed 60 Years Ago|last=Gruenberg|first=Mark|date=June 11, 2007|publisher=[[Political Affairs Magazine]]|access-date=2012-06-06|url-status=dead|archive-url=https://web.archive.org/web/20130518121009/http://www.politicalaffairs.net/taft-hartley-signed-60-years-ago/|archive-date=May 18, 2013}}</ref> The amendments maintained coverage under the act for professional employees, but provided for special procedures before they may be included in the same bargaining unit as non-professional employees.<ref>{{cite book|title=PUBLIC LAWS-CHS.114, 120-JUNE 21, 23,1947|publisher=80Ta CONG ., 1ST SESS .-CH. 120-JUNE 23, 1947|page=136|url=https://www.loc.gov/law/help/statutes-at-large/80th-congress/session-1/c80s1ch114.pdf}}</ref>

===Right of employer to oppose unions===
The act revised the Wagner Act's requirement of employer neutrality, to allow employers to deliver anti-union messages in the workplace.<ref name="McCarthy">Anna McCarthy, ''The Citizen Machine: Governing by Television in 1950s America'', New York: The New Press, 2010, p. 54. {{ISBN|978-1-59558-498-4}}.</ref> These changes confirmed an earlier [[Supreme Court of the United States|Supreme Court]] ruling that employers have a constitutional right to express their opposition to unions, so long as they did not threaten employees with reprisals for their union activities nor offer any incentives to employees as an alternative to unionizing. The amendments also gave employers the right to file a petition asking the board to determine if a union represents a majority of its employees, and allow employees to petition either to decertify their union, or to invalidate the union security provisions of any existing collective bargaining agreement.

===National Labor Relations Board===
{{Main|National Labor Relations Board}}
The amendments gave the general counsel of the National Labor Relations Board discretionary power to seek injunctions against either employers or unions that violated the act.{{citation needed|date=April 2015}} The law made pursuit of such injunctions mandatory, rather than discretionary, in the case of [[Secondary action|secondary boycotts]] by unions.{{citation needed|date=April 2015}} The amendments also established the general counsel's autonomy within the administrative framework of the NLRB. Congress also gave employers the right to sue unions for damages caused by a secondary boycott, but gave the general counsel exclusive power to seek injunctive relief against such activities.{{citation needed|date=April 2015}}

===Federal jurisdiction===
The act provided for federal court jurisdiction to enforce [[collective bargaining agreements]]. Although Congress passed this section to empower federal courts to hold unions liable in damages for strikes violating a no-strike clause, this part of the act has instead served as the springboard for creation of a "federal common law" of collective bargaining agreements, which favored [[arbitration]] over litigation or strikes as the preferred means of resolving labor disputes.{{citation needed|date=December 2012}}

===Conciliation Service===
The [[United States Conciliation Service]], which had provided mediation for labor disputes as part of Department of Labor, was removed from that department and reconstituted as an independent agency, the [[Federal Mediation and Conciliation Service (United States)]]. This was done in part because industry forces thought the existing service had been too "partial" to labor.<ref name="nyt-1947">{{cite news | last=Stark | first=Louis | url=https://www.nytimes.com/1947/06/24/archives/analysis-of-the-labor-act-shows-changed-era-at-hand-for-industry.html | title=Analysis of the Labor Act Shows Changed Era at Hand for Industry | newspaper=The New York Times | date=June 24, 1947 | pages=1, 4 }}</ref>

===Other===
The Congress that passed the Taft–Hartley Amendments considered repealing the [[Norris–La Guardia Act]] to the extent necessary to permit courts to issue injunctions against strikes violating a no-strike clause, but chose not to do so. The Supreme Court nonetheless held several decades later that the act implicitly gave the courts the power to enjoin such strikes over subjects that would be subject to final and binding arbitration under a collective bargaining agreement.

Finally, the act imposed a number of procedural and substantive standards that unions and employers must meet before they may use employer funds to provide pensions and other employee benefit to unionized employees. Congress has since passed more extensive protections for workers and employee benefit plans as part of the [[Employee Retirement Income Security Act]] ("ERISA").

==Aftermath==
[[File:Crowd carrying placards and a banner reading, "Repeal Taft-Hartley Act," and "Fair Tax elect Stevenson." (5278847529).jpg|thumb|1952 political march by the [[International Ladies Garment Workers Union]]; among their signs is "Repeal Hartley–Taft Act"]]
Union leaders in the [[Congress of Industrial Organizations]] (CIO) vigorously campaigned for Truman in the [[1948 United States presidential election|1948 election]] based upon a (never fulfilled) promise to repeal Taft–Hartley.<ref name=prisoners>{{cite book |last=Davis |first=Mike |title=Prisoners of the American Dream: Politics and Economy in the History of the US Working Class |publisher=W. W. Norton & Company |year=2000 |isbn=1-85984-248-8}}</ref> Truman won, but a union-backed effort in Ohio to defeat Taft in [[1950 United States Senate election in Ohio|1950]] failed in what one author described as "a shattering demonstration of labor's political weaknesses".<ref name="lubell1956">{{cite book |title=The Future of American Politics |publisher=Anchor Press |author=Lubell, Samuel |year=1956 |pages=202 |edition=2nd|ol = 6193934M}}</ref>

==See also==
* [[Labor unions in the United States]]
* [[Norris–La Guardia Act]]
* [[Wagner Act]]
* [[Jurisdictional strike]]
* [[Solidarity action]]
* ''[[Chauffeurs, Teamsters, and Helpers Local No. 391 v. Terry]]'', 494 U.S. 558 (1990) 5 to 2 on §185 of LMRA 1947, holding that a plaintiff is entitled to trial by jury if the trade union denies representation

==Notes==
{{Reflist}}

===Works cited===
* {{cite book |last1=Bowen |first1=Michael |title=The Roots of Modern Conservatism: Dewey, Taft, and the Battle for the Soul of the Republican Party |date=2011 |publisher=UNC Press Books |isbn=9780807869192}}
* {{cite book | last = McCoy | first = Donald R. | year = 1984 | title = The Presidency of Harry S. Truman | publisher = University Press of Kansas | isbn = 978-0-7006-0252-0 | url-access = registration | url = https://archive.org/details/presidencyofharr0000mcco }}

==References==
* Dean, Adam, and Jonathan Obert. "Rewarded by Friends and Punished by Enemies: The CIO and the Taft-Hartley Act." ''Labor'' 18.3 (2021): 78-113.

* McCann, Irving G. ''Why the Taft-Hartley Law?'' New York: [[National Committee to Uphold Constitutional Government|Committee for Constitutional Government]], 1950.
* Millis, Harry A. and Brown, Emily Clark. ''From the Wagner Act to Taft-Hartley: A Study of National Labor Policy and Labor Relations''. Chicago: University of Chicago Press, 1950.

==Further reading==
* Caballero, Raymond. ''McCarthyism vs. Clinton Jencks.'' Norman: University of Oklahoma Press, 2019.

==External links==
* [https://www.govinfo.gov/content/pkg/COMPS-8190/uslm/COMPS-8190.xml Labor Management Relations Act] ([https://www.govinfo.gov/content/pkg/COMPS-8190/pdf/COMPS-8190.pdf PDF]/[https://www.govinfo.gov/app/details/COMPS-8190/ details]) as amended in the [[United States Government Publishing Office|GPO]] [https://www.govinfo.gov/help/comps Statute Compilations collection]
* {{Internet Archive film clip|id=gov.archives.arc.95834|description="Longines Chronoscope with Fred A Hartley"}}

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[[Category:80th United States Congress]]
[[Category:1947 in American law]]
[[Category:1947 in economic history]]
[[Category:1947 in labor relations]]
[[Category:Anti-communism in the United States]]
[[Category:Trade union legislation]]
[[Category:United States federal labor legislation]]