In the United States v. Enmons et al., 1972, the Supreme Court ruled that labor union officials cannot be convicted under federal anti-extortion laws for demanding legitimate collective bargaining rights, even if they use aggressive tactics such as strikes or threats of strikes. The case arose when three officials from a local utility workers' union were indicted for extortion after threatening to strike unless their employer agreed to certain wage and pension demands. They argued that their actions were protected by federal labor law, which allows unions to bargain collectively on behalf of their members. The Supreme Court agreed with them in a 5-4 decision, holding that the Hobbs Act - an anti-racketeering law designed to combat organized crime - does not apply when union leaders are pursuing legitimate objectives through lawful means.

In the dissenting opinion for United States v. Enmons et al., Justice White, joined by Chief Justice Burger and Justices Blackmun and Rehnquist, argued that the majority's decision was a departure from previous interpretations of the Hobbs Act. They contended that it is not within the Court's jurisdiction to determine whether wage increases or improved working conditions are "legitimate" objectives; such determinations should be left to labor-management negotiations under federal labor laws. The dissenters believed that if union officials use force or threats of violence to achieve their goals, they should be held accountable under criminal law regardless of whether those goals could be considered legitimate in a different context. They expressed concern about potential implications for future cases involving violent conduct during strikes, suggesting this ruling might provide legal protection for such behavior.