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Like slavery, common law repression of labor unions was slow to be undone.[19] In 1806, Commonwealth v Pullis held that a Philadelphia shoemakers union striking for higher wages was an illegal "conspiracy",[20] even though corporations combinations of employers were lawful. Unions still formed and acted. The first federation of unions, the National Trades Union was established in 1834 to achieve a 10 hour working day, but it did not survive the soaring unemployment from the financial Panic of 1837.

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