constituted intimidation and, while
admitting that circumstances may alter cases, limited peaceful picketing
to one picket at each point of ingress or egress of the plant.[99] In
another case the Court held unconstitutional an Arizona statute, which
reproduced _verbatim_ the labor clauses of the Clayton Act;[100] this on
the ground that concerted action by the union would be illegal if the
means used were illegal and therefore the law which operated to make
them legal deprived the plaintiff of his property without due process of
law. In June 1922, in the Coronado case, the Court held that unions,
although unincorporated, are in every respect like corporations and are
liable for damages in their corporate capacity, including triple damages
under the Sherman Anti-Trust law, and which may be collected from their
funds.

We have already pointed out that since the War ended the American labor
movement has in the popular mind become linked with radicalism. The
steel strike and the coal miners' strike in 1919, the revolt against the
national leaders and "outlaw" strikes in the printing industry and on
the railways in 1920, the advocacy by the organizations of the railway
men of the Plumb Plan for nationalization of railways and its repeated
endorsement by the conventions of the American Federation of Labor, the
resolutions in favor of the nationalization of coal mines passed at the
conventions of the United Mine Workers, the "vacation" strike by the
anthracite coal miners in defiance of a government wage award, the
sympathy expressed for Soviet Russia in a number of unions, notably of
the clothing industry, have led many to see, despite the assertions of
the leaders of the American Federation of Labor to the contrary, an
apparent drift in the labor movement towards radicalism, or even the
probability of a radical majority in the Federation in the not distant
future.

The most startling shift has been, of course, in the railway men's
organizations, which have changed from a pronounced conservatism to an
advocacy of a socialistic plan of railway nationalization under the
Plumb Plan. The Plumb Plan raises the issue of socialism in its
American form. In bare outline the Plan proposes government acquisition
of the railroads at a value which excludes rights and privileges not
specifically granted to the roads in their charters from the States. The
government would then lease the roads to a private operating corporation
governed b