"Reed reviewed the enactment of the Federal Corrupt Practices Act in 1910 as well as its 1911 and 1925 amendments, the court's ruling in "Newberry v. United States", and the limitations imposed on unions' political expenditures by the 1943 War Labor Disputes Act.Quoting extensively from Congressional debates over Section 304 of the Taft-Hartley Act, Reed concluded that Congress clearly did not intend for the act to cover union newspapers supported by advertising or member subscriptions.