This guy's writing for a Law Review and he doesn't understand that a union is not only a group acting in restraint of trade but is a conspiracy to commit extortion. 100% illegal under the Common Law. Every union member is a criminal. Now their actions may have been rendered unpunishable, but as Joe Wambaugh said: "Getting rid of crime is easy, you just repeal criminal laws; but you don't get rid of evil that easily." Unions are intrinsically evil, and members are also. That's why peoples' professions of surprise at the latest (in an infinite line) of union violence and intimidation are so hilarious to those with 3-digit IQs. What a business owner ought to be free to do is to send his local union officers to sleep with Jimmie Hoffa.