In the case of H. A. Artists & Associates, Inc., et al. v. Actors' Equity Association et al., 1980, the Supreme Court ruled that labor unions have a right to impose restrictions on talent agents who represent their members in order to protect those members from exploitation and unfair practices by such agents. The court held that these restrictions are exempt from antitrust laws under the "labor exemption," which allows for collective bargaining activities that would otherwise be considered anti-competitive behavior. The dispute arose when a group of theatrical booking agencies sued Actors' Equity Association (AEA), alleging its rules governing relationships between actors and their agents were violating federal antitrust law by restricting competition among talent agencies. However, Justice William Brennan Jr., writing for the majority, stated that Congress intended to allow labor organizations considerable latitude in achieving their objectives through collective action; thus it was not an overreach for AEA to regulate agent fees as part of its efforts to improve working conditions and wages for actors.

In the dissenting opinion for H. A. Artists & Associates, Inc., v. Actors' Equity Association et al., Justice Powell argued that the majority's decision to uphold a union rule restricting talent agents from charging fees above those set by the union was inconsistent with previous Supreme Court rulings on labor law and antitrust exemptions. He contended that this ruling could potentially allow unions to dictate terms of employment contracts beyond their traditional scope, which would infringe upon individual liberties and free market principles. Furthermore, he expressed concern about potential conflicts of interest arising from unions having control over both sides of an employment contract negotiation process - representing workers while also regulating employers or intermediaries like talent agents.