National Labor Relations Board V. Town & Country Electric, Inc.: Allowing a Trojan Horse to Trample Employer Rights

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I. INTRODUCTION

Participation in labor unions in the United States is reaching historical lows.1 With the exception of a slight increase during 1993 and 1994, union membership has been declining since the early 1980s.2 The percentage of organized labor in the overall work force declined from 34.7% in 1954(3) to 15.5% in 1994.4 Several factors are responsible for the decline in union memberships. For example, the economy has changed from a manufacturing base to a service base, which has resulted in a loss of traditional union strength.5 Unions thus far have made little progress toward organizing the growing numbers of women and minorities in the work force.6 Additionally, the …