purpose that is not extortion, one of the key elements of a Hobbs Act violation is not met. Reactions Since 1973, a number of bills have been proposed by Republicans to overturn United States v. Enmons. The Freedom from Union Violence Act (FUVA) was first introduced by Rep. Phil Crane as H.R. 1796 on June 8, 1995, and was reintroduced three times; however, none of the bills made it out of committee. Despite the Court indicating that union officials are subject to criminal law ("This type of violence...is subject to state criminal prosecution"), think tanks which oppose unions claim the Enmons decision grants union officials exemption from criminal prosecution for acts of violence. However, subsequent to the decision, cases have been successfully brought under the Hobbs Act against union officials who engaged in extortion. On the extent of union violence, a 2001 law review article by law professor Julius Getman and former Secretary of Labor Ray Marshall, analyzing the evidence of union violence, indicated that:...the claim that strike violence is "escalating" has no empirical basis. Even the study conducted by the National Institute for Labor Relations Research - cited regularly as authority for this proposition by FUVA's proponents - draws no such conclusion. And the study itself is a scholarly monstrosity that seeks to study union violence by compiling media reports, mainly newspaper articles concerning strike violence. The Institute admits that it did not actually investigate any of the incidents reported and does not know if the reports are accurate. It concludes: "Because it relies on news accounts the Institute cannot guarantee the accuracy of the file itself." In fact, articles about employer-instigated violence are included in the study's effort to determine union violence. It seems obvious that the methodology employed confuses those strikes most written about with those most violent. Further, the Institute includes incidents of "psychological violence; i.e., intimidation, coercion and verbal threats" - terms which it does not bother to define. It seems clear, however, that this definition would include nonviolent civil disobedience of the type used by the civil rights movement and increasingly by the labor movement. But whatever the definition, it is almost certain that strike-related violence has decreased since the Enmons decision because the number of strikes has declined significantly. See also Entergy Corp. v. Riverkeeper Inc. Entergy Louisiana, Inc. v. Louisiana Public Service Commission Footnotes External links Small Business and Entrepreneurship Council: Union's