Secondary Consumer Picketing, Statutory Interpretation and the First Amendment

This Note examines both the statutory and constitutional implications of Safeco and Tree Fruits. It suggests that the confusion surrounding existing Board and court interpretations of section 8(b)(4)(ii)(B) stems from the Supreme Court’s failure to assess realistically the impact that consumer picketing has on secondary businesses, as well as the Court’s refusal to examine the objectives of unions that resort to secondary picketing.