In Adair v. United States (1908), the Supreme Court invalidated on Fifth Amendment due process grounds a federal act outlawing "__________" contracts, under which persons agreed, as a condition of employment, not to join labor unions.

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Yellow dog contracts were agreements between employees and employers where the employees would agree not to join a union or participate in any collective bargaining activities. The Supreme Court struck down federal laws outlawing yellow dog contracts in Adair v. United States, finding that they violated the Fifth Amendment's due process clause.

In Adair V