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Labor lawyers have learned from experience the inherent complexity of law-making in a federal system and the difficulties of anticipating the problems created by radiations of national regulation. Hill v. Florida, which held that a state statute licensing business agents conflicted with national protection of employees' free choice of bargaining representatives, demonstrated the reach and destructive power of those radiations. Bethlehem Steel Co. v. New York State Labor Relations Board, which barred New York from certifying a bargaining unit of foremen, suggested the presence of invisible radiations from denial of national protections. Congress in 1947 could not foresee, however, the problems projected by these decisions, particularly when federal law was changed from the unilateral limitations of the Wagner Act to the bilateral limitations of Taft-Hartley. The still-born cession clause of section 10(a) and the piecemeal provisions of section 14 proved wholly inadequate. Comprehensive national regulation carried unexpected implications for state law. Garner v. Teamsters Union found in the picketing provisions an implied prohibition of state restraints; and Guss v. Utah Labor Relations Board held that the cession clause designed to encourage cooperation between federal and state governments created a "no man's land" between them. The "Delphic nature' of Congressional silence has worked unexpected results, and the "process of litigating elucidation" has shed but a faltering light" revealing in many areas only the hazards that lie ahead.

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