Eric Eggen

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Gradually, and with much internal conflict, the courts were interpreting free labor only as a worker’s property right in his labor. It was thus both a “natural” right and subject to the constraints on property rights embodied in considerations of Salus populi. Workers could withhold their labor in strikes or boycotts, but not if such actions infringed on the rights of other workers, harmed public welfare, disrupted the rules of the market, or illegally diluted the value of an employer’s property.
The Republic for Which It Stands: The United States during Reconstruction and the Gilded Age, 1865-1896 (Oxford History of the United States)
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