National Right to Work Foundation Announces New Addition to Legal Team
Springfield, VA (July 25, 2011) – The National Right to Work Legal Defense Foundation announced today that Geoffrey MacLeay, formerly of Longwood, Florida, has joined its legal staff.
MacLeay is a member of the Florida state bar and a 2007 graduate of the Emory University School of Law.
“Geoffrey MacLeay brings a real commitment to defending employee rights against the ongoing threat of compulsory unionism,” said Ray LaJeunesse, vice president and legal director of the National Right to Work Foundation.
“Geoff is already helping to further develop the Foundation’s litigation program to counter organized labor’s well-funded attack on individual worker rights – from its coercive ‘card check’ organizing campaigns to the misuse of employees’ compulsory dues for politics.”
As the newest addition to the Right to Work legal team, MacLeay will help build on the Foundation’s record of litigation against compulsory unionism, which includes several precedent-setting cases decided by the United States Supreme Court. National Right to Work Foundation staff attorneys currently represent thousands of employees in nearly 200 active cases nationwide.
Before joining the Foundation, MacLeay worked for a public relations firm in Alexandria, Virginia, where he dealt with union issues, among others. Prior to that, he worked at the Center for Freedom and Prosperity, also in Alexandria.
After graduating from law school, MacLeay practiced law with a firm in Winter Park, Florida. He received a bachelor’s degree in history and political science from Tulane University in 2004.
Three Wisconsin Civil Servants Move to Intervene in Union Lawsuit to Support Walker Reforms
Madison, WI (July 19, 2011) – With the help of attorneys from the National Right to Work Legal Defense Foundation and the Wisconsin Institute for Law and Liberty, three Wisconsin civil servants have moved to intervene in a union lawsuit against Governor Scott Walker. The lawsuit, filed by lawyers from the AFL-CIO and Wisconsin Education Association Council (WEAC) union, challenges a recently-enacted law that would free public employees from paying union dues just to get or keep their jobs.
Foundation and Institute attorneys filed the motion today in United States District Court for Kristi Lacroix, a Wisconsin teacher at the LakeView Technology Academy, Nathan Berish, a teacher at Waukesha West High School, and Ricardo Cruz, a trust fund specialist at the Wisconsin Department of Employee Trust Funds.
Although Lacroix, Berish, and Cruz are not union members, their workplaces are subject to union monopoly bargaining, which means all three employees have been forced to pay union dues and accept union “representation” to keep their jobs.
Prior to the enactment of Wisconsin Act 10, the law union officials are challenging in court, Wisconsin civil servants could be forced to pay union dues and accept union workplace bargaining as a condition of employment. The new law, signed by Governor Walker, would prevent public sector union officials from collecting any money from nonunion workers, restrict union monopoly bargaining to the issue of employee wages, and end the use of taxpayer funded payroll systems for the collection of union dues.
Lacroix, Berish, and Cruz state that union officials are infringing on their freedom of association by forcing them to associate with and contribute money to organizations they have no interest in joining. They believe that their intervention is necessary to give voice to like-minded public employees while the lawsuit is being decided.
If granted, the employees’ motion to intervene would make them full participants in the lawsuit. LaCroix has already filed an amicus curiae brief opposing union lawyers’ attempt to block the law from going into effect.
“Many independent-minded civil servants have no interest in associating with or paying dues to public sector unions, and they deserve to have their voices heard because their rights are at stake in this case,” said Patrick Semmens, legal information director for the National Right to Work Foundation. “We hope these civil servants will be allowed to participate in a lawsuit that has far-reaching implications for all Wisconsin public employees.”
Worker: Why I sued Labor Secretary Hilda Solis
Chris Mosquera, a Maryland county government employee filed a federal lawsuit in May with free legal aid from National Right to Work Foundation staff attorneys to stop the Obama Administration from allowing union bosses to conceal lavish and corrupt union expenditures from workers.
In today’s Washington Examiner, Mosquera discussed why he filed the lawsuit against Secretary of Labor Hilda Solis:
As a member of the United Food and Commercial Workers union, I’m more knowledgeable than most about the ins and outs of union finance.
In fact, I’ve learned some interesting things about my own local’s spending habits over the years. Like the $2 million office condo they bought in Gaithersburg, or the fact that the president of my local makes over $200,000 a year, plus other undocumented benefits.
…
Disclosure is a simple but effective tool for fighting corruption and encouraging accountability. If union officials know their spending habits are part of the public record, they’ll be less interested in expensive getaways and more interested in effectively managing their members’ hard-earned dues.
Click here to read the entire op-ed.
For more of the Foundation’s coverage of the union-boss disclosures here, click here.
The Foundation relies completely on voluntary contributions from its supporters to provide free legal aid. To make a tax-deductible contribution in whatever amount, please click here.
The Right to Work: A Fundamental Freedom
The following article by National Right to Work Legel Defense Foundation President Mark Mix appeared in the June/July issue of Imprimis, a publication of Hillsdale College sent each month to 1.9 million subscribers. The article is adapted from a lecture given at Hillsdale College in January 2011.
The Right to Work: A Fundamental Freedom
BOEING IS A GREAT AMERICAN COMPANY. Recently it has built a second production line—its other is in Washington State—in South Carolina for its 787 Dreamliner airplane, creating 1,000 jobs there so far. Who knows what factors led to its decision to do this? As with all such business decisions, there were many. But the National Labor Relations Board (NLRB)—a five-member agency created in 1935 by the Wagner Act (about which I will speak momentarily)—has taken exception to this decision, ultimately based on the fact that South Carolina is a right-to-work state. That is, South Carolina, like 21 other states today, protects a worker’s right not only to join a union, but also to make the choice not to join or financially support a union. Washington State does not. The general counsel of the NLRB, on behalf of the International Association of Machinists union, has issued a complaint against Boeing, which, if successful, would require it to move its South Carolina operation back to Washington State. This would represent an unprecedented act of intervention by the federal government that appears, on its face, un-American. But it is an act long in the making, and boils down to a fundamental misunderstanding of freedom.
Where does this story begin?
The Wagner Act and Taft-Hartley
In 1935, Congress passed and President Franklin Roosevelt signed into law the National Labor Relations Act (NLRA), commonly referred to as the Wagner Act after its Senate sponsor, New York Democrat Robert Wagner. Section 7 of the Wagner Act states:
Employees shall have the right to self-organization, to form, join, or assist labor organizations, to bargain collectively through representatives of their own choosing, and to engage in other concerted activities for the purpose of collective bargaining or other mutual aid or protection.
Union officials such as William Green, president of the American Federation of Labor (AFL), and John L. Lewis, principal founder of the Congress of Industrial Organizations (CIO), hailed this legislation at the time as the “Magna Carta of Labor.” But in fact it was far from a charter of liberty for working Americans.
Section 8(3) of the Wagner Act allowed for “agreements” between employers and officers of a union requiring union membership “as a condition of employment” if the union was certified or recognized as the employees’ “exclusive” bargaining agent on matters of pay, benefits, and work rules. On its face, this violates the clear principle that the freedom to associate necessarily includes the freedom not to associate. In other words, the Wagner Act didn’t protect the freedom of workers because it didn’t allow for them to decide against union membership. To be sure, the Wagner Act left states the prerogative to protect employees from compulsory union membership. But federal law was decidedly one-sided: Firing or refusing to hire a worker because he or she had joined a union was a federal crime, whereas firing or refusing to hire a worker for not joining a union with “exclusive” bargaining privileges was federally protected. The National Labor Relations Board was created by the Wagner Act to enforce these policies.
During World War II, FDR’s War Labor Board aggressively promoted compulsory union membership. By the end of the war, the vast majority of unionized workers in America were covered by contracts requiring them to belong to a union in order to keep their jobs. But Americans were coming to see compulsory union membership—euphemistically referred to as “union security”—as a violation of the freedom of association. Furthermore, the nonchalance with which union bosses like John L. Lewis paralyzed the economy by calling employees out on strike in 1946 hardened public support for the right to work as opposed to compulsory unionism. As Gilbert J. Gall, a staunch proponent of the latter, acknowledged in a monograph chronicling legislative battles over this issue from the 1940s on, “the huge post-war strike wave and other problems of reconversion gave an added impetus to right-to-work proposals.”
When dozens of senators and congressmen who backed compulsory unionism were ousted in the 1946 election, the new Republican leaders of Congress had a clear opportunity to curb the legal power of union bosses to force workers to join unions. Instead, they opted for a compromise that they thought would have enough congressional support to override a presidential veto by President Truman. Thus Section 7 of the revised National Labor Relations Act of 1947—commonly referred to as the Taft-Hartley Act—only appears at first to represent an improvement over Section 7 of the Wagner Act. It begins:
Employees shall have the right to self-organization, to form, join, or assist labor organizations, to bargain collectively through representatives of their own choosing, and to engage in other concerted activities for the purpose of collective bargaining or other mutual aid or protection, and shall also have the right to refrain from any and all such activities. . . .
Had this sentence ended there, forced union membership would have been prohibited, and at the same time voluntary union membership would have remained protected. Unfortunately, the sentence continued:
…except to the extent that such right may be affected by an agreement requiring membership in a labor organization as a condition of employment as authorized in section 158(a)(3) of this title.
This qualification, placing federal policy firmly on the side of compulsory union membership, left workers little better off than they were under the Wagner Act. Elsewhere, Taft-Hartley did, for the most part, prohibit “closed shop” arrangements that forced workers to join a union before being hired. But they could still be forced to join, on threat of being fired, within a few weeks after starting on the job.
Boeing’s Interest, and Ours
It cannot be overemphasized that compulsory unionism violates the first principle of the original labor union movement in America. Samuel Gompers, founder and first president of the AFL, wrote that the labor movement was “based upon the recognition of the sovereignty of the worker.” Officers of the AFL, he explained in the American Federationist, can “suggest” or “recommend,” but they “cannot command one man in America to do anything.” He continued: “Under no circumstances can they say, ‘you must do so and so, or, ‘you must desist from doing so and so.’” In a series of Federationist editorials published during World War I, Gompers opposed various government mandate measures being considered in the capitals of industrial states like Massachusetts and New York that would have mandated certain provisions for manual laborers and other select groups of workers:The workers of America adhere to voluntary institutions in preference to compulsory systems which are held to be not only impractical but a menace to their rights, welfare and their liberty.
This argument applies as much to compulsory unionism—or “union security”—as to the opposite idea that unions should be prohibited. And in a December 1918 address before the Council on Foreign Relations, Gompers made this point explicitly:
There may be here and there a worker who for certain reasons unexplainable to us does not join a union of labor. This is his right no matter how morally wrong he may be. It is his legal right and no one can dare question his exercise of that legal right.
Compare Gompers’s traditional American view of freedom to the contemptuous view toward workers of labor leaders today. Here is United Food and Commercial Workers union strategist Joe Crump advising union organizers in a 1991 trade journal article: “Employees are complex and unpredictable. Employers are simple and predictable. Organize employers, not employees.” And in 2005, Mike Fishman, head of the Service Employees International Union, was even more blunt. When it comes to union organizing campaigns, he told the Wall Street Journal, “We don’t do elections.”
Under a decades-old political compromise, federal labor policies promoting compulsory unionism persist side by side with the ability of states to curb such compulsion with right-to-work laws. So far, as I said, 22 states have done so. And when we compare and contrast the economic performance in these 22 states against the others, we find interesting things. For example, from 1999 to 2009 (the last such year for which data are available), the aggregate real all-industry GDP of the 22 right-to-work states grew by 24.2 percent, nearly 40 percent more than the gain registered by the other 28 states as a group.
Even more dramatic is the contrast if we look at personal income growth. From 2000 to 2010, real personal incomes grew by an average of 24.3 percent in the 22 right-to-work states, more than double the rate for the other 28 as a group. But the strongest indicator is the migration of young adults. In 2009, there were 20 percent more 25- to 34-year-olds in right-to-work states than in 1999. In the compulsory union states, the increase was only 3.3 percent—barely one-sixth as much.
In this context, the decision by Boeing to open a plant in South Carolina may be not only in its own best interest, but in ours as well. So in whose interest is the National Labor Relations Board acting? And more importantly, with a view to what understanding of freedom?
Public Sector Unionism
As more and more workers and businesses have obtained refuge from compulsory unionism in right-to-work states in recent decades, the rationality of the free market has been showing itself. But the public sector is another and a grimmer story.
The National Labor Relations Act affects only private-sector workers. Since the 1960s, however, 21 states have enacted laws authorizing the collection of forced union dues from at least some state and local public employees. More than a dozen additional states have granted union officials the monopoly power to speak for all government workers whether they consent to this or not. Thus today, government workers are more than five times as likely to be unionized as private sector workers. This represents a great danger for taxpayers and consumers of government services. For as Victor Gotbaum, head of the Manhattan-based District 37 of the American Federation of State, County and Municipal Employees union, said 36 years ago: “We have the ability, in a sense, to elect our own boss.”
How this works is simple, and explains the inordinate power of union officials in so many states that have not adopted right-to-work laws. Union officials funnel a huge portion of the compulsory dues and fees they collect into efforts to influence the outcomes of elections. In return, elected officials are afraid to anger them even in the face of financial crisis. This explains why states with the heaviest tax burdens and the greatest long-term fiscal imbalances (in many cases due to bloated public employee pension funds) are those with the most unionized government workforces. California, Illinois, Massachusetts, Michigan, Nevada, New Jersey, New York, Ohio and Wisconsin represent the worst default risks among the 50 states. In 2010, an average of 59.2 percent of the public employees in these nine worst default-risk states were unionized, 19.2 percentage points higher than the national average of 40 percent. All of these states except Nevada authorize compulsory union dues and fees in the public sector.
* * *
Fortunately, there are signs that taxpayers are recognizing the negative consequences of compulsory unionism in the public sector. Just this March, legislatures in Wisconsin and Ohio revoked compulsory powers of government union bosses, and similar efforts are underway in several other states. Furthermore, the NLRB’s blatantly political and un-constitutional power play with regard to Boeing’s South Carolina production line is sure to strike fair-minded Americans as beyond the pale. Now more than ever, it is time to push home the point that all American workers in all 50 states should be granted the full freedom of association—which includes the freedom not to associate—in the area of union membership.
Reprinted by permission from Imprimis, a publication of Hillsdale College.
Federal Labor Board Ruling Ends Discriminatory Teamster Policy against Nonunion Employees
Washington, DC (July 6, 2011) – The National Labor Relations Board (NLRB), a federal agency charged with administering private sector labor law, has ruled against a Teamsters workplace policy that discriminated against nonunion workers. Kirk Rammage, the victim of union officials’ discriminatory practices, received free assistance from the National Right to Work Foundation during his extended legal battle.
Although the NLRB previously decided the case in Rammage’s favor in 2009, that ruling was later nullified by the Supreme Court on the grounds that the Board lacked a three member quorum at the time of the decision.
Rammage, an Interstate Bakeries employee from Ponca City, Oklahoma, was involved in the consolidation of two separate corporate divisions in 2005. Part of one division was staffed by a single nonunion sales representative – Rammage – who had put in more time with Interstate Bakeries than any of his coworkers at the office where he worked. Although the company wanted to retain Rammage and protect his seniority during the merger, union bosses from Teamsters Local 523 demanded that union members receive preferential treatment, putting Rammage at the bottom of the seniority roster despite his workplace tenure.
At Interstate Bakeries, seniority increases employees’ chances of securing desirable sales routes and getting more time off. By insisting that Rammage lose his seniority, Teamster officials effectively signaled that union workers took priority over their nonunion colleagues.
After revisiting the facts of the case, the NLRB again concluded that Teamster officials broke the law by discriminating against employees based on their union representation status. However, the Obama Board’s new decision outlines a way for union officials to get around the National Labor Relations Act’s anti-discrimination provisions, indicating that union officials could have lawfully ignored Rammage’s tenure if they had claimed it was because he had no preexisting, enforceable seniority instead of saying it was because he wasn’t previously subject to union monopoly bargaining.
“Teamster bosses discriminated against a nonunion worker because he had the temerity not to associate with their union,” said Patrick Semmens, Legal Information Director for the National Right to Work Foundation. “While we’re pleased to report that the Board has finally gotten around to reaffirming Kirk Rammage’s rights, the Obama NLRB still managed to show its pro-compulsory unionism bias by taking the opportunity to provide union bosses with a roadmap for ‘legally’ discriminating against non-union employees in similar situations in the future.”
Federal Labor Board Finds Merit to Charges against Union for Forcing Nurses to Join, Pay Full Dues
Seattle, Washington (July 5, 2011) – The National Labor Relations Board (NLRB), a federal agency responsible for administering private sector labor law, has found merit to charges filed by two Virginia Mason Medical Center nurses against the Washington State Nurses Association (WSNA) union. The charges, which were filed for the nurses by National Right to Work Foundation attorneys, state that WSNA officials automatically enrolled nurses in the union without their consent and forced them to pay full union dues.
By finding merit to the charges, the National Labor Relations Board has signaled that WSNA officials must enter into a unit-wide settlement that protects nurses’ rights or face prosecution. The NLRB also agrees that a provision in the union’s contract limiting nurses’ right to resign is unlawful.
Therese Mollerus-Gale still works at Virginia Mason Medical Center while Maureen Lenahan has since resigned her position to accompany her husband to his next military posting. Because Washington lacks a Right to Work law, employees like Lenahan and Mollerus-Gale can be forced to pay union dues or fees as a condition of employment. However, the Foundation-won Supreme Court precedent Communication Workers v. Beck holds that nonunion employees cannot be charged for union activities unrelated to workplace bargaining, such as members-only events and political activism.
Meanwhile, another nurse has stepped forward to file new unfair labor practice charges against the WSNA union. According to Amber Finn, who also works at Virginia Mason, WSNA officials ignored her letter requesting nonmember status, enrolled her as a union member without her consent, and threatened to have her fired for refusing to pay full dues.
WSNA officials also resorted to frivolous procedural tactics to prevent Finn from leaving the union, ignoring her resignation letter because she didn’t submit it via certified mail. Moreover, WSNA officials failed to provide nurses with an independently-audited breakdown of union expenditures, which is required by law to help nonunion employees determine what dues they have to pay as a condition of keeping their jobs.
The NLRB will now investigate Finn’s charges against the union.
“Hard-working nurses shouldn’t be pushed into union ranks and forced to pay tribute to WSNA bosses just to keep their jobs,” said Patrick Semmens, Legal Information Director for the National Right to Work Foundation. “Nobody should have to pay union dues or join a union just to make a living, which is why Washington needs to make union membership and dues payment strictly voluntary by passing a Right to Work law immediately.”
News Release: Teamster Union Bosses Hit with Federal Charges for Having Coca-Cola Worker Illegally Fired
Teamster Union Bosses Hit with Federal Charges for Having Coca-Cola Worker Illegally Fired
Incident shows Pennsylvania’s workers desperately need Right to Work protections
Houston, PA (July 5, 2011) – With free legal assistance from the National Right to Work Foundation, a former Coca-Cola employee has filed federal charges against a local Teamster union and the company for discrimination and illegally firing him from his job.
Keith Smiesko of Saxonburg filed the federal charges with the National Labor Relations Board (NLRB) regional office in Pittsburgh on Thursday.
Earlier this year, Teamster Local 585 union officials ordered Smiesko – who had refrained from full union membership and dues payments – to immediately pay full union dues for the previous three years along with additional union initiation fees without ever notifying him that he was being charged for their so-called “representation.” Union officials illegally threatened Smiesko with job termination if he did not pay.
Smiesko refused, exercising his rights under the Foundation-won Supreme Court precedent in Communication Workers v. Beck, which allows workers to refrain from full-dues-paying union membership. Teamster Local 585 union officials then demanded that Coca-Cola fire Smiesko and Coca-Cola complied with the union bosses’ command.
Teamster Union Bosses Hit with Federal Charges for Having Coca-Cola Worker Illegally Fired
Houston, PA (July 5, 2011) – With free legal assistance from the National Right to Work Foundation, a former Coca-Cola employee has filed federal charges against a local Teamster union and the company for discrimination and illegally firing him from his job.
Keith Smiesko of Saxonburg filed the federal charges with the National Labor Relations Board (NLRB) regional office in Pittsburgh on Thursday.
Earlier this year, Teamster Local 585 union officials ordered Smiesko – who had refrained from full union membership and dues payments – to immediately pay full union dues for the previous three years along with additional union initiation fees without ever notifying him that he was being charged for their so-called “representation.” Union officials illegally threatened Smiesko with job termination if he did not pay.
Smiesko refused, exercising his rights under the Foundation-won Supreme Court precedent in Communication Workers v. Beck, which allows workers to refrain from full-dues-paying union membership. Teamster Local 585 union officials then demanded that Coca-Cola fire Smiesko and Coca-Cola complied with the union bosses’ command.
Smiesko also seeks to be reinstated immediately to his job with Coca-Cola while the case is pending.
“No worker should ever be extorted by union bosses to join or pay dues to a union in order to get or keep a job,” said Mark Mix, President of National Right to Work. “Pennsylvania desperately needs Right to Work protections for its workers to strip from predatory union bosses the power to compel workers to give up some of their hard-earned money they need to provide for their families.”
Despite the Court precedent in Beck, union bosses can still force workers who refrain from formal union membership into paying part of union dues because Pennsylvania does not have a Right to Work law. However they cannot compel workers to pay the portion of union dues used for the union’s political, lobbying, and member-only activities.
If enacted, a Right to Work law would end compulsory union dues by making union membership and dues payment strictly voluntary. Polls consistently show that 8 in 10 Americans support the Right to Work principle, that no worker should be compelled to join a union or pay union dues to get or keep a job. Twenty-two states have already passed Right to Work protections for their workers.
Right to Work Attorneys Demand Workers’ Voices Be Heard on Obama NLRB Rule Change
Last week, President Obama’s National Labor Relations Board (NLRB) proposed new guidelines which will help give union organizers the upper hand over independent-minded employees, and make union organizing campaigns as one-sided as possible.
The new rules, which are designed to allow union organizers to browbeat workers into union ranks and keep independent workers from opposing unionization, make it easier for union organizers to launch stealth campaigns in which they have access to the personal information of workers and harass them (including by making "home visits") into signing "union authorization cards."
Meanwhile, the vast majority of workers and the employer may have no idea what is happening.
Then, after union organizers collect those "authorization cards" from just 30 percent of employees in the workplace, workers would be ambushed with an union organizing election in just days — denying independent-minded employees any time to share truthful, non-coercive information with their coworkers about the effects of unionization.
Well-funded professional union organizers regularly push for unionization behind the scenes for months (or even years) as part of their drive for more forced union dues, and under the new rules, workers wishing to remain free from union boss control would only have days to counter what could be years of union-boss propaganda being used at their workplace — and even at their coworkers’ homes.
Further, even if union bosses don’t think they can win the quickie election, under the new rules they would be able to request the election in order to force the employer to hand over a list of every employee with their home address, phone number, email and shift information. Armed with this information union organizers could then withdraw the election petition and continue pursuing their coercive card check campaign.
In response, the National Right to Work Foundation has requested to address the NLRB at its public hearing next month on the proposed rule changes. If allowed, Foundation staff attorneys will argue at the hearing that the ambush elections Big Labor is pushing for would prevent independent-minded workers their right to resist forced unionization of their workplace and that the rule requiring job providers to hand over the employees’ personal information to union bosses is a violation of their privacy and places them in danger of harassment at the hands of aggressive union organizers.
You can read the Foundation’s request to appear at the NLRB’s public meeting on behalf of independent-minded workers here (pdf).
News Release: Teacher Files Brief in Wisconsin Government Unionism Reform Battle in Federal Court
Teacher Files Brief in Wisconsin Government Unionism Reform Battle in Federal Court
Public-sector union bosses file desperate lawsuit seeking to protect forced dues stranglehold over Wisconsin’s public workers and taxpayers
Madison, WI (June 29, 2011) – With free legal assistance from the National Right to Work Foundation and the Wisconsin Institute for Law & Liberty, a Kenosha teacher affected by Wisconsin’s recent public-sector unionism reforms has filed an amicus curiae brief in federal court.
Kristi Lacroix, who has been a teacher for 13 years and is an English teacher at the LakeView Technology Academy in Pleasant Prairie, filed the brief Monday in favor of the reforms which sharply limited government union officials’ monopoly bargaining power over public workers and taxpayers.
Earlier this month, the Wisconsin Supreme Court upheld Governor Scott Walker’s government-sector monopoly bargaining reform bill, which protects the Right to Work for most government employees and bans automatic forced-union-dues seizures from public employees’ paychecks.
In response, union lawyers filed a new lawsuit in federal court seeking to overturn the bill, claiming that Freedom of Association – the right of American citizens to voluntarily come together to express their opinions and petition the government – gives union bosses forced-dues and monopoly bargaining powers.
Foundation staff attorneys have won at the United States Supreme Court numerous times on this very issue, winning precedents that support the constitutionality of Wisconsin’s government-sector monopoly bargaining reform bill.
