“…In this hostile legal climate, the simple act of joining a union, striking, or boycotting could be interpreted as an unlawful conspiracy in restraint of trade, against which employers regularly secured injunctions restricting, if not prohibiting, most such forms of collective action prior to the New Deal (McCammon 1993). When the law was not enough, employers, often with backing from the state, violently attacked labor, resulting in some 500 strike-related deaths in the three decades following the 1894 national Pullman strike (Lipold and Isaac 2009), placing the United States on a par with post-Bismarck Germany and ahead of most of Europe in the high level of repression directed at labor (Goldstein 2010).…”