William O. Douglas

“ In those narrow and specialized circumstances, I see no answer to the power of the Board in its discretion to impose the checkoff as 'affirmative action' necessary to remedy the flagrant refusal of the employer to bargain in good faith.
The case is rare, if not unique, and will seldom arise. I realize that any principle once announced may in time gain a momentum not warranted by the exigencies of its creation. But once there is any business consideration that leads to a denial of a demand or any consideration of bargaining strategy that explains the refusal, the Board has no power to act. ”