union officials could act as they saw fit, regardless of the sentiment of general membership. Collective bargaining Likewise, the Act addressed the issue of collective bargaining but only in externalities such as reporting thereof. It did not address the question of whether such agreements required any consent from the union members or locals. Furthermore, in allowing for trusteeship in such instances, the Act allowed for union officials to exert greater control over the will of their members. In one court case on the matter, an Oklahoma City local attempted to leave one union body to affiliate with another. The original union put it under trusteeship to block the transfer, and the court upheld the move as legal under the Act. As law professor Alan Hyde put it, "the courts advance democratic bargaining only when assured that such democracy will not disadvantage more fundamental policy interests, such as harmony between employers and 'unions' (read union elites) or control of inflation." Pensions With regard to retiree pensions, among other secondary issues, the Act did nothing to close the loophole created by the National Labor Relations Act to allow such 'permissive' or 'not mandatory' items from being dealt with by a union employer unilaterally, a right which was upheld by the Supreme Court as late as 1971 in Allied Chemical Workers Local 1 v. Pittsburgh Plate Glass Company. Likewise, in 1980, the Supreme Court affirmed the right of union international offices to negotiate a pension plan in conflict with that supported by the members when union bylaws allowed for approval by international. Persuader Rule President Barack Obama used the Act as authority to issue the "Persuader Rule", which required an employer's attorney to publicly disclose advice provided to persuade against unionization. The National Federation of Independent Business sued and, on November 16, 2016, U.S. District Judge Samuel Ray Cummings issued a permanent nationwide injunction blocking the Persuader Rule, finding it was not authorized by the Act, and that it violated the First Amendment to the United States Constitution. See also US labor law National Labor Relations Act of 1935, the "Wagner Act" Taft–Hartley Act (Labor Management Relations Act of 1947) List of United States federal legislation Notes References JR Bellace and AD Berkowitz, The Landrum–Griffin Act: Twenty Years of Federal Protection of Union Members' Rights (1979). 363 pp. H Benson, 'The Fight for Union Democracy' in SM Lipset, ed. Unions in Transition: Entering