in the corporate or other forms of ownership association", the NLRA 1935 codified basic rights of employees to organize a union, requires employers to bargain in good faith (at least on paper) after a union has majority support, binds employers to collective agreements, and protects the right to take collective action including a strike. Union membership, collective bargaining, and standards of living all increased rapidly until Congress forced through the Taft-Hartley Act of 1947. Its amendments enabled states to pass laws restricting agreements for all employees in a workplace to be unionized, prohibited collective action against associated employers, and introduced a list of unfair labor practices for unions, as well as employers. Since then, the US Supreme Court chose to develop a doctrine that the rules in the NLRA 1935 preempted any other state rules if an activity was "arguably subject" to its rights and duties. While states were inhibited from acting as "laboratories of democracy", and particularly as unions were targeted from 1980 and membership fell, the NLRA 1935 has been criticized as a "failed statute" as US labor law "ossified". This has led to more innovative experiments among states, progressive corporations and unions to create direct participation rights, including the right to vote for or codetermine directors of corporate boards, and elect work councils with binding rights on workplace issues. Labor unions Freedom of association in labor unions has always been fundamental to the development of democratic society, and is protected by the First Amendment to the Constitution. In early colonial history, labor unions were routinely suppressed by the government. Recorded instances include cart drivers being fined for striking in 1677 in New York City, and carpenters prosecuted as criminals for striking in Savannah, Georgia in 1746. After the American Revolution, however, courts departed from repressive elements of English common law. The first reported case, Commonwealth v Pullis in 1806 did find shoemakers in Philadelphia guilty of "a combination to raise their wages". Nevertheless, unions continued, and the first federation of trade unions was formed in 1834, the National Trades' Union, with the primary aim of a 10-hour working day. In 1842 the Supreme Court of Massachusetts held in Commonwealth v Hunt that a strike by the Boston Journeymen Bootmakers' Society for higher wages was lawful. Chief Justice Shaw held that people "are free to work for whom they please, or not to work, if they so prefer"