1979•The University of Chicago Law ReviewRequires access
Consumer Picketing and the Single-Product Secondary Employer
Barbara E. Snyder
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Abstract
United Paperworkers Local 832 (Duro Paper Bag Mfg.Co.), 236 N.L.R. B. 1525 (1978) (paper bags used to bag groceries).The Board and court in American Bread reasoned that the struck bread lost its identity in being served as part of a meal, since "[tlhe customer in the restaruant either takes the meal as offered, or goes elsewhere for a meal"; hence, a purported product boycott against the bread was in reality an attempt to coerce the secondary restaurants by persuading customers to eat elsewhere.170 N.L.R.B. at 93.The Duro Paper Bag Board distinguished American Bread, concluding that the struck bags did not lose their separate identity since cartons were sometimes (not always) available and since other customers brought their own containers.236