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Abstract

The controversy intensified after the Supreme Court decision in NLRB v. Bildisco and Bildisco. The decision outraged union leaders and led to the passage of 11 U.S.C. § 1113. This comment will explore the issues arising from efforts by businesses to reject or modify collective bargaining agreements under section 1113. The comment will review the history of such efforts, and will then discuss the Bildisco decision. The comment will then examine section 1113 and offer suggestions as to its interpretation.

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