In the autumn of 1921 the employers in the packing industry discontinued the arrangement whereby industrial relations were administered by an "administrator,"[94] Judge Alschuler of Chicago, whose rulings had materially restricted the employers' control in the shop. Some of the employers put into effect company union plans. This led to a strike, but in the end the unions lost their foothold in the industry, which the War had enabled them to acquire. By that time, however, the open-shop movement seemed already passing its peak, without having caused an irreparable breach in the position of organized labor. Evidently, the long years of preparation before the War and the great opportunity during the War itself, if they have failed to give trade unionism the position of a recognized national institution, have at least made it immune from destruction by employers, however general or skillfully managed the attack. In 1920 the total organized union membership, including the 871,000 in unions unaffiliated with the American Federation of Labor, was slightly short of 5,000,000, or over four million in the Federation itself. In 1921 the membership of the Federation declined slightly to 3,906,000, and the total organized membership probably in proportion. In 1922 the membership of the Federation declined to about 3,200,000, showing a loss of about 850,000 since the high mark of 1920. The legal position of trade unions has continued as uncertain and unsatisfactory to the unions, as if no Clayton Act had been passed. The closed shop has been condemned as coercion of non-unionists. Yet in the Coppage case[95] the United States Supreme Court found that it is not coercion when an employer threatens discharge unless union membership is renounced. Similarly, it is unlawful for union agents to attempt organization, even by peaceful persuasion, when employes have signed contracts not to join the union as a condition of employment.[96] A decision which arouses strong doubt whether the Clayton Act made any change in the status of trade unions was given by the Supreme Court in the recent Duplex Printing case.[97] In this decision the union rested its defense squarely on the immunities granted by the Clayton Act. Despite this, the injunction was confirmed and the boycott again declared illegal, the court holding that the words "employer and employes" in the Act restrict its benefits only to "parties standing in proximate relation to a controversy," that is to the employes who are immediately involved in the dispute and not to the national union which undertakes to bring their employer to terms by causing their other members to boycott his goods.