Blackmail and extortion: the choice between paying money (or some non-monetary good or deed) or risk suffering an unpleasant action. A common error is to use the phrase "Hobbesian choice" instead of "Hobson's choice", confusing the philosopher Thomas Hobbes with the relatively obscure Thomas Hobson. (It is possible the confusion is between "Hobson's choice" and a "Hobbesian trap", which refers to the situation in which a state attacks another out of fear.) Common law In Immigration and Naturalization Service v. Chadha (1983), Justice Byron White dissented and classified the majority's decision to strike down the "one-house veto" as unconstitutional as leaving Congress with a Hobson's choice. Congress may choose between "refrain[ing] from delegating the necessary authority, leaving itself with a hopeless task of writing laws with the requisite specificity to cover endless special circumstances across the entire policy landscape, or in the alternative, to abdicate its lawmaking function to the executive branch and independent agency". In Philadelphia v. New Jersey, 437 U.S. 617 (1978), the majority opinion ruled that a New Jersey law which prohibited the importation of solid or liquid waste from other states into New Jersey was unconstitutional based on the Commerce Clause. The majority reasoned that New Jersey cannot discriminate between the intrastate waste and the interstate waste without due justification. In dissent, Justice Rehnquist stated: In Monell v. Department of Social Services of the City of New York, 436 U.S. 658 (1978) the judgement of the court was that In the South African Constitutional Case MEC for Education, Kwa-Zulu Natal and Others v Pillay, 2008 (1) SA 474 (CC) Chief Justice Langa for the majority of the Court (in Paragraph 62 of the judgement) writes that: In Epic Systems Corp. v. Lewis (2018), Justice Ruth Bader Ginsburg dissented and added in one of the footnotes that the petitioners "faced a Hobson’s choice: accept arbitration on their employer’s terms or give up their jobs". In In Meriwether v. Hartop, the court addressed the university's offer, "Don’t use any pronouns or sex-based terms at all." It wrote, "The effect of this Hobson’s Choice is that Meriwether must adhere to the university’s orthodoxy (or face punishment). This is coercion, at the very least of the indirect sort." In popular culture Film and Television Hobson's Choice (play), by Harold Brighouse (1915), which has been adapted numerous times: Hobson's Choice (1920 film), a silent film directed by Percy Nash Hobson's Choice