Union Power and Government Aid; S. Petro

UNION POWER, AND GOVERNMENT AID UNION POWER over the last sixty years has varied in ac cordance with the privileges and immunities which gov ernments in this country have given trade unionists. One is tempted to go further and say that government has responded to more or less clear shifts in public opinion. But the situation is more complicated than that. The problem of ends and means is universal in politi cal economy. Though there may be agreement concern ing ends, policy judgments all involve choices among means. A proper choice of means requires a degree of knowledge and sophistication far beyond that which the general public possesses. These limitations rule any dis cussion of the role of public opinion. One may say that opinion rules all governmental action, but the problem is-whose opinion?-and how? As a logical matter, union membership and union power need not necessarily vary in direct proportion Dr. Petro is Professor of Law at New York University School of Law. For an elaboration of his suggestions on putting the prin ciples of freedom to work in labor relations, see The Labor Policy of the Free Society (New York: Ronald Press, 1957).

144 UNION POWER AND GOVERNMENT AID 145 with each other. Quite -the contrary is possible-union power might increase while membership declined, or vice versa. There are other problems of definition. In the ab stract, union power might be defined as the capacity of unions to gain their ends. More concretely and realis tically, it means the ability of unions to extract immedi ately from employers and ultimately from society and the consumers a greater return for the efforts of union leaders and members than a free market would accord them. Power so defined will vary from union to union, so that gross membership of all unions does not necessarily correspond to the total power of all unions. Yet, as will appear more clearly later, there is a definite relationship between union membership and union power. Growth of union membership and increase of union power come from the same source: special privileges and immunities granted by governments.

The Growth of Me111bership Union membership has grown in this country from 440,000 in 1897 to 17,024,000 in 1959. The 1959 figure includes all AFL-CIO unions and all independent na tional and international unions with reported U. S. mem bership in excess of 100,000. Canadian members are excluded. It will not do, however, to notice only the extremes. Significant insights are to be derived from looking at what happened in between: 146 SYLVESTER PETRO Years Number of Members 1910 2,116,000 1915 2,560,000 1920 5,034,000 1925 3,566,000 1930 3,632,000 1935 3,728,000 1936 4,164,000 1937 7,218,000 1938 8,265,000 1939 8,980,000 1940 8,944,000 1941 10,489,000 1942 10,762,000 1943 13,642,000 1944 14,621,000 1945 14,796,000 1946 14,974,000 1947 15,414,000 Not much has happened since 1947. While unions to day claim, as has been noted, a total membership of 17,000,000, even if that claim is credited the figure would suggest that union membership as a percentage of the labor force has lost ground in the last thirteen years.

Certainly there has been a great preoccupation among the top men of the AFL-CIO over the fact that unions have at best, from their point of view, stood still, and at worst seriously lost ground since World War II ended. If newspaper stories are to be credited, there was much UNION POWER AND GOVERNMENT AID 147 head-shaking amid the palms at Bal Harbour, Florida, in February, where the dedicated men of the AFL-CIO met to ponder their problems. A story by Mr. A. H. Raskin in The New York Times (Feb. 10, 1960, p. 16) quotes John W. Livingston, the federation's organizing director, as attributing the sad situation to "ferocious attacks" by employer groups and "labor's" inability to overcome internal feuds. The unionized sector is sup posed to represent only 39 per cent of the organizable potential today-as against 40 per cent in 1955. Plans to combat the decline include stepped-up organizing and a vigorous approach to the resolution of interunion rivalries.

If the conclusions I have derived from study of our labor law history are accurate, these measures are not likely to prove effective without positive government assistance and connivance. For nothing emerges more clearly and convincingly from that history, in my opinion, than the conclusion that unions unaided by government cannot induce substantial numbers of the working force to become and to remain members. They need compulsion and coercion in order to get and keep great numbers of members, and these they can exercise only when government does not do its basic duty to society. I could be wrong on this, although I think I am not. But even if unions can induce great numbers to be come members, without special privileges of compulsion and violence they can get no better wages and working conditions than the free market would provide. If that 148 SYLVESTER PETRO is true, I cannot see why they should be successful in keeping great numbers, if we as a nation deny unions the privilege of compulsion.

The essential basis of the general conclusion can be stated briefly and simply:· during the period when the laws of the land were applied with some rigor to trade union action, unions made little or no net progress in enlisting and keeping members; they about kept pace with the growth of the labor force. But when all branches of government came to the assistance of the unions, their membership growth was dramatic. Then, when law and its administration became a little more even-handed, unions were once again unable to achieve any material growth. The key period in union growth covered the years 1935-1945, and more particularly 1936-1940 and 1942 1943. But before exploring the relevant events of those periods it will be well to broaden the perspective. We shall not be able properly to evaluate the governmental conduct of those key periods unless we have some basis of comparison. Government and Unions: 1800-1917 From the beginning of our history as a nation till World War I, trade unionism was viewed by law and government as no different from other forms of volun tary association. Today's orthodoxy, although it is losing some of its dogmatic confidence, continues to insist that trade unions were dealt with unfairly by the common UNION POWER AND GOVERNMENT AID 149 law, and by state and federal governments. But this po sition rests upon mere assertion. The fact is that govern ment, even with the best will in the world, has always had trouble applying the laws of the land to trade union action. At common law, unions were not considered suable entities and could therefore not be reached by ordinary suits at law. Violence has always been a feature of trade union organization and collective bargaining, and local police have always had an extremely-difficult time keeping the peace in labor disputes.

Perhaps unions should have been outlawed as criminal conspiracies, but, current orthodoxy to the contrary not withstanding, neither the common law nor legislation actually did so. Hence unions as such were allowed to survive in spite of their having committed the most viciously antisocial kinds of acts. Indeed, Eugene Debs was virtually canonized even in his own day, although he was guilty of the worst kind of defiance of law and order. Still, it was pretty well understood, at least among the responsible members of society and of government, that trade unions had no special privilege to violate either the basic laws of civilization or the rules and prin ciples of the common law. There was a good deal of un certainty among common-law courts as to just where the line ought to be drawn as regards such forms of mo nopolistic coercion as the closed shop, secondary boycotts, and stranger picketing. But that uncertainty existed, I believe, because of the essential difficulty of the legal problem-not because the courts were intent upon pro150 SYLVESTER PETRO viding special privileges for union coercion. The impor tant thing was that there was no uncertainty at all as regards the impermissibility of outright violence. Courts were firm on that issue, and even the police and the politicians were of the view that a man was not entitled to use violence merely because he was a trade union officer or agent.

Almost equally important, the common-law rights of employers were still intact. They could refuse to hire a man because he was a union member; hire him only on conditi?n that he refrain from union membership; and fire any employee for joining a union. Employers could also refuse to bargain with unions, just as they could refuse to bargain with any other person or agency. Beginning in the 1890's and continuing into the 1930's, trade-union expansionism also had to contend with the antitrust laws. These laws did not explicitly or directly limit monopoly-type coercive organizing techniques, but in putting limits upon certain kinds of secondary boy cotts they did have an indirect effect of that kind, for secondary boycotts have always been used mainly as or ganizing devices. While the antitrust laws did not apply to union violence, they did constitute a limit upon industry-wide strikes where it could be shown that the intention was to affect market prices.

To sum up on the conditions existing till roughly World War 1, one may say that unions were in the same position, legally, as all other self-interest groups. We might call this the period of free competition. Unions had no special privileges or immunities. They could use UNION POWER AND GOVERNMENT AID 151 some forms of monopolistic coercion in order to compel membership and bargaining. But the government did not do their organizing for them, and it did not force any employer to bargain with them. Perhaps even more important, employers still had intact the freedom of contract which was so essential a feature of the common law scheme of things. Today we consider it vital that as purchasers we re main free to, break off relations with any seller who does not suit us. This, we recognize, is what keeps business men serving the public, rather than exploiting it. In those days it was considered equally vital that the pur chasers of labor have a right to break off relationships with unions when they proved unreliable or exploita tive suppliers of labor. The famous Hitchman Coal case, which held that employers had a constitutional right to condition employment on a promise by employees not to join unions, was perhaps the clearest expression of the then prevailing policy.

In this period of what I have called "free competi tion," trade unions survived and even grew, but their growth was anything but spectacular. By 1917 they had gained a membership of less than three million (2,976,000). Government and Unions: World War II From 1917 to 1920 unions grew to a little over five million members. In 1914, however, a significant event had occurred. Devoting serious effort to political action, 152 SYLVESTER PETRO unionists achieved a substantial success 'when Congress passed the Clayton Act, in 1914. The Clayton Act did not, in fact, free unions from the strictures of either the Sherman Act or the equity powers of the federal courts. As regards both, the legal situation changed not at all, for the Supreme Court in the Duplex and the TriCity cases held that the Clayton Act was merely declaratory of existing law. And yet merely securing the Clayton Act was a substantial success. Moreover, it originated a pat tern of thought and action, especially in Congress, which continues to this day: a predisposition to deal very gently with union petitions and complaints.

Another familiar pattern was set in the early days of World War I: Unions utilized the emergency in order to exact concessions from the nation. Professors Harry A. Millis and Royal E. Montgomery have long been identified as friends of the "labor move ment." We may assume that their account of the policies adopted during World War I was not distorted by a bias against unions. In their carefully researched book, Or ganized Labor (McGraw-Hill, 1945), they reported quite candidly that the AFL leaders conditioned their support of the war effort on the government's recognition of "the organized labor movement as the agency through which it must cooperate with the wage-earners." (p. 136) The government agreed. When it began organizing the vari ous bureaucracies which were to run the country during the war, the government accorded suitable recognition to Mr. Samuel Compers and his associates in the "labor movement." They were key figures in the Council of UNION POWER AND GOVERNMENT AID 153 National Defense, the Emergency Construction Board, the Fuel Administration, the powerful War Industries Board and other such agencies. (p. 138) In this period the basic features of the Railway Labor Act and the Wagner Act were conceived: compulsory collective bargaining and protection of workers against discharge for union membership. Compulsory arbitra tion was not used during World War I, but the govern ment's mediation agencies, counting trade-union leaders among their members, paid due regard to union de mands. Millis and Montgomery sum up the situation: "Organized labor made only one real concession-re linquishment of the right to strike-but it made this concession in general terms, with no penalties attached.

In such a setting, the trade union growth that has al ready been summarized was almost inevitable." (p. 139) Incidentally, the unions did not honor their no-strike pledge during World War I any more faithfully than they did during World War 11.1 1 There were. 3,789 work stoppages in 1916, in 1917 there were 4,450, and in 1918 there were 3,353. Taking the years 1935~39 as base years with an index of 100, 1916 shows up with an index num ber of 132 for work stoppages and 142 for number of workers in volved; 1917 shows up with 155 and 109, respectively; and 1918, 117 and 110. These levels were not attained again till 1937, the year in which the Wagner-Act policies took hold. And after 1937, till 1941, work stoppages and number of workers involved did not come near what the unions ~chieved during World War 1. How ever, they surpassed their old record of wartime strikes for two of the years of World War II (for 1944 and 1945 the figures were 173 and 188 and 166 and 308, respectively). The other years, 1941 43 averaged about the same in terms of number of work stoppages, but substantially higher in terms of number of workers involved (1941: 150 and 210; 1942: 104 and 75; 1943: 131 and 176). (Bureau of Labor Statistics figures) 154 SYLVESTER PETRO Lest accurate perspective be lost, special emphasis should be laid upon the fact that during World War I, while government lent administrative aid and prestige to the unions, the basic legal structure remained un changed: neither statutory nor common-law principles were modified. When the war ended, the basic rules of the competitive society once more became applicable.

Probably for this reason, union membership declined after the war ended, and remained down for the next fifteen years. Government and Unions: 1920-1935 Total union membership fell from 5,034,000 in 1920 to 3,728,000 in 1935. Some have suggested that the de pression caused this drop, but that explanation is un acceptable. Actually, union membership remained steady at about 3,500,000 from 1923 on, having fallen from 5 million in 1920 to 3,629,000 in 1923. The real explana tion, I feel, lies in the fact that government was giving unions no great assistance during the years 1920-1935. The implication is that without such special assistance unions could not keep more than about three and a half million members enrolled. While government aid to unions was limited in this period, it will not do to neglect the steps which were taken in the direction of special privilege. Two were especially significant. The first of these was the enact ment of the Railway Labor Act in 1926, establishing for the first time the statutory principles of protection UNION POWER AND GOVERNMENT AID 155 of union membership and of compulsory collective bar gaining between employers and the majority representa tives of their employees. The second was the Norris LaGuardia Act of 1932, which made it virtually impossi ble for employers to secure injunctive relief in the fed eral courts against monopolistically coercive union boy cotts, and extremely difficult to secure such relief from even outright union violence.

Both statutes contained latent features which were in the succeeding years to transform conditions in labor relations. The elemental compulsory bargaining princi ples of the Railway Labor Act were to become the frame work of the Wagner Act. The restrictive features of the Norris Act were to produce antitrust exemptions for unions. Perhaps even more important, in taking away the jurisdiction of the federal courts the Norris Act estab lished the pattern which was to make labor relations an administrative law field, with the National Labor Relations Board the dominant agency. From this a great many serious and untoward consequences flowed. But these were to be realized only in the years after 1935. Till then, neither the Railway Labor Act nor the Norris Act provided enough special privilege for unions to achieve any dramatic growth. Government and Unions: 1935-1947 Between 1935 and 1947 unions achieved the goal of every special interest group: a full, even overfull, com plement of legal rights and privileges-with no corres156 SYLVESTER PETRO ponding legal duties. As already noted, they did very well in terms of membership gains. From a membership of 3,728,000 in 1935 they acquired a membership of over 15,000,000 in 1947. The dramatic character of this increment can be appreciated only when one sets it against· a near-stable membership of under four million for the preceding thirty-five years.

Every branch of government came to the assistance of the unions during this period. Legislatures, state and federal, gave them favorable laws. Administrations, espe cially those of the national government, enforced these favorable laws well beyond the hilt. And the Supreme Court of the United States not only went along with distorted interpretations of already unduly favorable laws, but also established constitutional privileges for such coercive union action as picketing. The favoritism did not diminish during the emergency years of World War II. On the contrary, it tended to expand. Unions did little to hide their intentions to profit from the emergency. I think it ,is not a distortion to say that, al though union leaders talked a great deal about patriot ism, they did not act the part of patriots. Fundamentally what happened in the years 1935-1947 is that most of the effective free market checks to forced union growth were destroyed at the same time that the most effective legal restraints upon aggressive and com pulsory unionism were removed. To put it another way, peaceful and lawful resistance to unionization was pro hibited in one way or another, while violent and unlaw ful action by unions went substantially unchecked.

UNION POWER AND GOVERNMENT AID 157 Free market checks to expansive unionism can come from two sources: (a) employees who prefer not to join unions, and (b) employers who find that dealing with unions is neither an effective nor economically feasible method of solving their personnel problems. The Wagner Act of 1935 did not completely abolish either of these checks, but it impaired them considerably. If a majority of employees in an appropriate bargaining unit voted in favor of union representation, the minority was left with no choice other than to accept the union as exclusive bargaining representative. When one realizes that the selection of the appropriate bargaining unit was left to the almost unhampered discretion of the National Labor Relations Board-and that the Board thought its duty was to carve out the bargaining unit which was most likely to result in the election of a union-one is likely to conclude that a great deal of gerrymandering went on. That conclusion is affirmed by examination of the cases.

After a union was certified as exclusive bargaining representative, the employer was under a duty to bargain with that union-and with no other-on all matters re lating to wages, hours, and other terms and conditions of employment. The employer did not have the choice which a free market makes available to all other pur chasers; he could not shop around; he had to bargain with that one agency. Thus it is proper to refer to the union's position as a monopolistic one.· And the results to be expected from all such monopolies were forthcom ing in labor relations. Unions abused their position.

158 SYLVESTER PETRO Violence Tolerated Unfortunately, the monopolistic privileges of unions did not end there. Legally, an employer could refuse to make the concessions sought by the exclusive bargaining agent. Moreover, if the bargaining agent called a strike in order to reinforce its demands, the employer had a legal right to attempt to keep his plant operating by hiring replacements for the strikers. The law has always provided, too, that a union could not use violence during strikes as a means of blocking the access of struck em ployers to the labor market. As a practical matter, how ever, owing to faulty and inadequate enforcement of the laws, unions had a virtual privilege to commit violence. The sitdown strikes are a memorial to some of the black est days for law enforcement in the history of the coun try. The tenor of the thirties is nowhere more clearly symbolized, in my opinion, than in the history of Frank l\tlurphy's career. As Governor of Michigan it was his sworn duty to prevent the violence and the sitdown strikes of the UAW. He flouted that duty. He was re warded, not punished, for that dereliction. Franklin De lano Roosevelt appointed him a justice of the highest court of law in the nation after he had been guilty of cynically abusing the law of the land. As a justice of the Supreme Court, one of Mr. Murphy's most notable opinions was the one in Thornhill v. Alabama (1940), where he held in effect that a coercive union act, picket ing, was entitled to the protection of the Constitution of the United States as a form of freedom of speech.

UNION POWER AND GOVERNMENT AID 159 The favorable-to-unions legal climate was not limited to the removal of the checks which employers and non union employees might pose to expansive and aggres sive unionism. The Norris Act had been on the federal statute books since 1932, preventing federal courts from granting injunctive relief to beleaguered employers and employees. There were similar statutes in most of the states, especially the more industrialized states. Toward the end of the thirties and early in the forties the Su preme Court interpreted the Norris Act as in effect can celing the application of the antitrust laws to monopo listically coercive union activities. The picketing-free speech doctrine in a rough sort of way tended to free the unions from state laws prohibiting picketing and boycotts. Thus, at the same time that the Wagner Act preached in terms of majority rule, the absence of all checks upon picketing and secondary boycotts operated to give unions an unimpeded right to force themselves upon unwilling employers and employees even where none of the employees desired representation. The same immunity made it possible for unions to have their way more often than not in disputes with employers over substantive terms and conditions of employment.

With Govern111entAid If the strong unions were in a position to extend their organizations to the limit, nobody should be surprised. And if they had the strength to impose almost any terms and conditions they pleased, nobody should be surprised, 160 SYLVESTER PETRO either. They had acquired a privileged monopoly and they did not intend to let it go unused. Let me remind the reader that union membership grew· from 3,728,000 in 1935 to 10,489,000 in 1940. The surprising thing is that these highly privileged organizations did not man age to unionize every employee during that period. Enrolling union members is one thing; keeping them on the membership rolls is another. Apparently this was the great problem of the union leaders during the war years. Their efforts during 1942-1945 seemed to be di rected' most vigorously toward inducing the National War Labor Board to help them organize employees and then, by way of the maintenance of a membership device which the WLB evolved, to keep them paying dues.

Millis and Montgomery report in Organized Labor that as time wore on the WLB granted "union security" to all unions which requested it, except where the "re questing union failed to demonstrate its responsibility in adhering to the no-strike pledge." (p. 764) In blunter language, the government bought the loyalty of the union leaders by compelling employees to maintain their union membership. I t seems permissible to infer that the WLB proved exceedingly serviceable to the unions during the war, for there is a remarkable jump in union membership from 1942 to 1943. In the years preceding as well as in those following 1942-1943, the growth is nothing like what occurred in those years. From 10,489,000 in 1941, unions grew to only 10,762,000 in 1942. But by 1943 the figure jumped to 13,642,000. Then the growth rate, UNION POWER AND GOVERNMENT AID 161 while still significant, slipped a little from 1943 to 1944, when the total membership has been counted at 14,621,000.

There has been no really marked union growth since then. In that fact lies the basis for some really interest ing reflection. Why have unions stopped growing since roughly the end of World War II? Government and Unions: 1947 to Date The easy answer would be that the Taft-Hartley Act, enacted in 1947, did the job. But I am dissatisfied with such an answer. At the very .least it is necessary to note that there' has heen other legislation,· especially on the state level, which like the Taft-Hartley Act has taken a stand against compulsory unionism. The right.,.to-work laws are perhaps the most significant. But even when one adds to Taft-Hartley all the state and local laws designed to cut down· the privileged coercion which unions . enjoyed well into the forties, the fact remains that both national and state legislation has been by no means vigorously enforced against. unions. My book, en titled How the NLRB Repealed Taft-Hartley~ records my opinion that the Taft-Hartley Act was by no means faithfully applied. The opinion is common, moreover, that the right-to-work laws have not been widely re spected. Finally, a good .. many of the special privileges which unions enjoyed prior to Taft-Hartley they enjoy equally today-as, for example, exemption from the anti trust laws, and the privilege of· stranger picketing which 162 SYLVESTER PETRO the Supreme Court's pre-emption doctrine affords.

If unions have stopped growing even though they still enjoy special privileges from government, does it follow that the special privileges did not account for their great growth in the thirties and early forties? I think not. The most important fact to bear in mind here is that govern ment has not since 1947-and earlier in some states-been single-mindedly on the side of the unions as it was during the preceding period. State and federal law now takes the position, subject to some qualification, that unions are no more justified in coercing people into unions than employers are in coercing them out of unions. Union restraint or coercion of free employee choice is just as illegitimate as employer coercion of that choice. This limitation on aggressive union organizing is sup plemented in national and state policies by measures which reinvigorate the most effective free-market checks to expansive unionism: those posed by employees and employers unwilling to submit to union domination.

Employees are declared to have the right to refuse to join unions or to participate in concerted activities; em ployers have had restored their right to combat union ism with statements of antiunion opinion-so long as they do not contain threats of reprisal or force or prom ises of benefit. Even though the new restraints upon union aggres sion have not been enforced as vigorously as they might have been in all cases, they have still had a substantial effect. One need only review the decisions of the N a tional Labor Relations Board and of the state and fedUNION POWER AND GOVERNMENT AID 163 eral courts over the last thirteen years in order to see that aggressive unionism has frequently encountered legal restrictions. In thousands of cases during that period unions have been prevented by the law from im posing their will upon unwilling employees and resist ing employers. The Taft-Hartley Act and similar state legislation have not broken unions or reduced them sig nificantly in size and numbers, but it seems clear that they have had a braking effect. Many types of picketing and boycotting have remained privileged; much violence has continued. But numerous instances of each kind of aggression have been hindered or completely prevented.

And this fact, I conclude, has mainly accounted for the observable halt in union growth. There have been other, closely integrated causes. As a general rule it seems to be extremely difficult for large organizations to maintain great growth rates after a cer tain point has been reached. Accretions seem to become progressively more difficult. The easiest segments of the working force were organized first; now the difficult ones are left. If one must organize the more difficult ones with fewer effective instruments than were available when the easier ones were brought into the fold, the results are not likely to be so good. Finally-concurrently with law changes and the phe nomenon just noted-public opinion at every level has changed. The common working men, the professional men, political figures, even academic intellectuals have come to. a more realistic opinion concerning unions. Many continue to feel that unionization is "good for 164 SYLVESTER PETRO the country," that unions are needed in order to keep employers from abusing workers. But very few people today are of the opinion that unions can do no wrong, perhaps workingmen least of all. With "public opinion"

so oriented, it is too much to expect that all the special privileges which unions enjoy will be repealed in the near future. However, courts and administrators are more likely under these conditions to apply the existing law fairly and accurately to unions; and in those cases where legislation is not entirely clear, one may reason ably expect that they will not favor an interpretation which adds to union privileges, as they did so often in the past. If public opinion, speaking generally, at once holds unionism a "good thing" but distrusts union leaders, the immediate legislative results are likely to be neither clear-cut nor healthy. One may expect the same kind of fragmentary, incoherent legislative approach which has occurred in connection with the regulation of busi ness. In fact this process has already begun. I contended in an article in National Review (March 26, 1960) that the Landrum-Griffin Law is bad legislation, bad in de tail and unwholesome· in general approach. It takes the government further along the interventionist path, and its detail is so complex as to be incomprehensible at points. The same thing can be said of much business regulation-most notably, perhaps, the Robinson-Patman Act.

If we continue along the route marked by such legis lation as Robinson-Patman and Landrum-Griffin, we UNION POWER AND GOVERNMENT AID 165 shall, I believe, eventually break down in one way or another. We shall either strangle ourselves in bureau cratic red tape, corrupt our bureaucracy so that we can get something done, or so hamper the activity of our private associations that full socialism will seem the only reasonable way out. The realistic alternative is to rid ourselves of special privilege and the companion welfare-state idea that gov ernment is an all-purpose device fit to solve all our prob lems. In order to do this it is necessary to refute all totalitarian ideas, whether of the Marxian or Keynesian varieties, and to take up again the development of free market principles with a full understanding of the theory and practice of the free society. Although Marxism and New Dealism have enjoyed great victories in the past generation, the strange fact is that the theory of the free society has, although very quietly, made great strides during the same period.

Those who wish to promote free enterprise will do well to acquaint themselves with the great literature of the free society, not only of past centuries, but of this one as well. Some of the best of the current literature is to be found in the writings of Friedrich Hayek, Henry Haz litt, Ludwig von Mises, and Wilhelm Roepke. But there has been much more, as perusal of Henry Hazlitt's bibli ography, The Free Man's Library~ will demonstrate. Further improvement in the climate of labor relations can come only as individuals better understand, explain, and practice in their daily living the economic and moral principles of the free society.