Since the passing of the Sherman Anti-Trust Act in 1890 there has been an enormous increase in litigation concerning the trade union and its activities. When the Supreme Court in the Danbury Hatters' case8 held that labor organizations were included in the provisions of the Sherman Act, and that the so-called "secondary boycott"' was a violation of the terms of this act, labor felt that it had lost a very effective weapon and at once began to fear that the very existence of the labor union was in danger. Not having much hope of relief from the courts, the forces of labor began a campaign to procure relief by way of legislative enactment. This culminated in 1914 in the passing by Congress of the Clayton Act, which was hailed by the labor unions as their "Magna Charta" and their "Bill of Rights." Whatever justification there was for such satisfaction and optimism, their hopes were crushed by the decision in the Duplex case in 1920.