...Section 6 of the Clayton Act further provides that neither such organizations nor their members "shall be held or construed to be illegal combinations or...conspiracies in restraint of trade under the antitrust laws."7 By its terms, the Section 6 exemption applies only to cooperatives "not having capital stock";...

.... [of their organizations]", and. finally, that no labor organization or its members should be held "to be illegal combinations or conspiracies in restraint of trade, under the antitrust laws." Section 20 purported to forbid the federal courts from granting restraining orders or injunctions in...

...organizations from lawfully carrying out the legitimate objects thereof; nor shall such organization, or the members thereof, be held or construed to be...in restraint of trade, under the antitrust laws." We are convinced, therefore, because of the fundamentally different nature of agriculture, and because...

...permitted the "existence and operation of labor, agricultural or horticultural associations" without being "construed to be illegal combinations or conspiracies in restraint of trade under the antitrust laws." The Act covered only nonstock marketing associations. Subsequent private antitrust actions and threatened...

...carrying out the legitimate objects thereof; and such organizations, or the members thereof, shall not be held or construed to be illegal combinations or conspiracies in restraint of trade, under this chapter. The labor of a human being is not a commodity or article of commerce. (2) This chapter...

...organizations, ... or to forbid or restrain individual members of such organizations from lawfully carrying out the legitimate objects thereof; nor shall such...conspiracies in restraint of trade, under the antitrust laws. 410 TULANE LAW REVIEW [Vol. 53 injunction jurisdiction in labor disputes.7' But labor's celebration...

...organizations, ... or to forbid or restrain individual members of such organizations from lawfully carrying out the legitimate objects thereof; nor shall such organizations, or the members thereof, be hold or construed to be illegal combinations or conspiracies in restraint of trade, under the antitrust...

...expressly provides that neither labor organizations nor the members of labor organizations may be held to be illegal combinations or conspiracies in restraint of trade under the antitrust laws.2 Section 20 of the Clayton Act3 provides that a federal court may not issue an injunction, except...

...for profit, or to forbid or restrain individual members of such organizations from lawfully carrying out the legitimate objects thereof; nor shall such...in restraint of trade, under the antitrust laws." 25 Clayton Act § 20; 29 USC § 52. A threshold issue is whether the group claiming the labor exemption...

...labor . . . organizations, instituted for the purposes of mutual help." Nor shall these organizations "be held or construed to be illegal combinations or...in restraint of trade, under the antitrust laws." In an effort to stop the continuing use of injunctions against union activities, the legislation said...