Worker/Management Cooperation: Going Forward
© 1999 John Perkins
The Electromation case crystallized the tensions embedded in the
Wagner Act. In the non-unionize workplace, management needs a way to
to workers about issues of "mutual interest" while, at the same
time, workers need a genuine, and independent, way to decide who shall
them at any "talks" with management. The huge middle ground left
in the Wagner Act, either vote to have a union or have nothing, has
many proposals. I will look at proposals from three sources: legal
the Dunlop Commission, and Congress (the TEAM Act). In the last section
I will present my own recommendations based on these sources.
Articles in law journals first brought my attention to the importance
the Electromation case. Martin Moe's article in the New York Law Review
on the implication of Electromation, maintained that the Board missed a
critical opportunity to settle this part of labor law. To Moe, the
conceptual splitting of issues of "quality" from "conditions
of employment" misconstrues the realities of the modern workplace.
"Wages, rates of pay, hours of employment, and conditions of work are
intimately related to productivity and efficiency and, in fact, may be
factors in improving productivity and efficiency."1
Moe also chastises the Board for failing to find a representational
in interpreting Section 2(5). By only looking at Cabot Carbon, the
lost a chance to view the role of employees in a bilateral
committee in a larger context. From this line of argument Moe concluded:
The shortcomings of Electromation and its progeny
that the NLRB must reformulate standards for Section 2(5) and 8(a)(2)
provide clear guidance for employers and employees and take into
the great differences between the company unions of the 1930s and
modes of employee involvement. Because over eighty-seven percent of the
United States' private sector workforce is not unionized, the Board's
interpretation leaves the vast majority of American workers with an
(and unproductive) choice-representation by a traditional independent
or no collective voice in the processes and conditions of the
This Note argues that the Board's outdated and inflexible statutory
should be jettisoned in favor of an interpretation that both preserves
autonomy and grants employers and employees the opportunity to utilize
beneficial ways of cooperating in the workplace.2
According to Moe, neither the circuit courts nor Congress will be the
to reinterpret the Wagner Act as needed for modern workplace practices.
The Board ignores contrary circuit court findings because of its
to uphold a uniform national labor policy; and "the chances are high
that any significant legislative proposal to amend the Wagner Act will
mired in political stalemate"3-witness the fate of the TEAM Act
later in this paper.
Central to Moe's proposed reinterpretation of Section 2(5) is a
that the Board define representation and then follow its definition.
offered three criteria: (1) the degree to which alleged worker
were formally (e.g., by election or nomination) designated
of other workers; (2) evidence that employees believe the employee
speaks in its behalf; and (3) the amount of evidence that the employer
up the program, with employer initiation weighing against a finding of
Moe's suggestion for reinterpreting Section 8(a)(2) pivots on how the
view the situation, and that the Board needs to make a distinction
cooperation and domination. He suggests that a cooperative arrangement,
with clear assurances from management to employees that they can have
independent bargaining agent of their own choosing would leave the way
for workers to accept a scheme of representation which does not involve
an outside union, if it is one that they like.5
This proposal will not work for many workers since they do not trust
"clear assurances" of management.6 This proposal ignores the dominate
role management attitudes play in the minds of workers. In addition, in
actual practice, workers seeking a change would still face the same
and political difficulties (including hostile management attitudes) of
workplace governance practices they have now. By offering only
the option of establishing "cooperative arrangements" without
workers being able to vote on the form of representation they prefer,
circles back to the very issues joined in the Electromation case which
is trying to solve.
Another legal scholar, Mark Barenberg, found a different tack for
a way forward. Where Moe would dive into the law and remake it by
Barenberg rises above it, and seeks resolution to the problems of
voice in the nonunion workplace by creating new fora for broadening the
discussion. Barenberg's solution includes three main components:
Institutional component: Regional "Centers for Advanced
Barenberg offers a novel approach for a mechanism for weaving these
and gradually moving our workplace environment from one of low-trust to
one of higher trust with increased worker choice and improved
government facilitated deliberative conferences. Barenberg thinks "the
legal regime should afford employees a protected forum, radically
from the day-to-day context of employer authority, in which they can
discuss their workplace governance options." Barenberg is sensitive
to the needs for workers to have a place to talk, and think, away from
"property and presence of management and employer-aligned consultants."8
Self-Governance Component: Ensuring Workers' Active Choice Among
Process Component: Formal, Nonadversarial "Conferences for Employee
Barenberg is fully aware that decisions about workplace governance
in a context of asymmetric power, and his proposals deliberately tip
scales in favor of employees in order to redress that power imbalance.
need places to deliberate on the various governance schemes available
them away from the pressures and sentiments of management. For
after deliberation, workers can pick a governance structure close to a
union" if they want it that way, but they would have to actively affirm
their choice in a secret ballot election.9
As part of this overall readjustment to a high-trust environment,
would require workers to actively choose among workplace governance
at designated intervals. This restores a policy used in 1933-35 when
chose among a variety of workplace representation plans. By requiring a
vote, this proposal creates an opportunity for workers to consciously
upon the dangers of "manipulation and paternalism (as well as the
benefits)" inherent in such schemes.10 Second, the process of
will help workers prepare themselves to monitor the good faith of both
representatives and management. A third point Barenberg makes,
by the Survey results mentioned in the first section, is that workers
non-union workplaces who formally endorse a representational scheme
probably be more intrinsically committed to its success.
Barenberg sees his conference concept, or what he calls regional
Centers, as creating
as pure a setting for egalitarian, informed deliberation as
is possible in a highly impure world. If we are socially committed to
employees the free collective choice of workplace governance modes-and,
in principle, we already are-then the choice is surely better made in
proposed setting than in furtive fragmented meetings or under the
surveillance of a party (the employer) capable of inflicting great cost
on the choosers.11 (Emphasis in original).
Another benefit from Barenberg's conference idea will be the creation
a robust "market" for unions, employees associations and other
labor-oriented consultants who can be hired by the conference staff to
conferences and help employees understand their governance options. He
that the UAW and CWA already have sophisticated methods for determining
job-design and career-development needs for various work groups and the
conference scheme would encourage mobilized unions and emergent forms
employee organizations to get involved.12
Barenberg believes that the New Deal labor boards did not want to
the adversarial worker-management relationships so prevalent at the
of the drafting of the Wagner Act. In his conference scheme, the staff
the Participation Center would provide a "watchdog" role currently
missing in employee deliberations. It could intervene on the spot to
charges of misrepresentation and the very presence of Participation
staff would keep management from overtly intimidating their employees
any group discussion in which management participates. By returning to
pre-Taft-Hartley ban on employer discussions of major workplace
decisions-except in the context of discussions held at Participation
hopes to soften the "inherently coercive nature of anti-union
and supervisory speeches in the captive-audience setting of the
Barenberg, an expert on New Deal labor legislation, believes his
restore the original pragmatic vision of Robert Wagner. He concludes
Thus, the institutional, symbolic, and resource-incentive
of the new regime of labor law would cumulatively encourage the
from low-trust, low-productivity to high-trust, high performance
More important, the new legal policy would concurrently disseminate
continuous-learning work processes and promote employee's capacities
individual self-revision, organization redesign, and collective
The law, that is, would safeguard workers against organizational forms
a high potential for structural coercion, distorted communication, and
manipulation, and would facilitate, although not guarantee,
through employees collective empowerment. The new legal regime would
Senator Robert Wagner's radical pragmatist vision to the economic and
possibilities in the crisis of bureaucratic production.14
The Dunlop Commission
After the Electromation decision President Clinton appointed The
for the Future of Worker-Management Relations (the Dunlop Commission).
had thirteen members. Its chair, John Dunlop, is the eminent
specialist and a former Secretary of Labor. Its Chief Counsel, Paul
of Harvard Law School, has had a series of comprehensive reform
disseminated within the legal academic community.15 Other members
former Secretaries of Labor and Commerce, former Presidents of major
organizations, CEO's of corporations, and labor-management relations
from academic institutions. Though the Commission's membership
the "heavy weights" and well-organized portions of the workforce
well, it did not have anyone voicing the concerns of large un-organized
workforces such as farm workers.
On March 24, 1993, when the Secretaries of Labor and Commerce announced
the formation of this Commission, they charged it with answering three
1. What (if any) new methods or institutions should be
encouraged, or required, to enhance work-place productivity
through labor-management cooperation and employee
2. What (if any) changes should be made in the present
legal framework and practices of collective bargaining to
enhance cooperative behavior, improve productivity, and
reduce conflict and delay?
3. What (if anything) should be done to increase the extent
to which work-place problems are directly resolved by the
parties themselves, rather than through recourse to state
and federal courts and government regulatory bodies?16
This Commission issued a Fact Finding Report on June 2, 1994, followed
a public hearing and statement period which lasted through November 14,
1994. The Commission sought the widest possible comments on its Fact
Report. The overall totals are impressive: 411 witnesses at 21 public
which, after transcription, ran to 4,681 pages; more than 160
entered into the record; and numerous other studies and presentations.17
In Sections 1 and 2 of its Final Report, the Commission discussed the
society places on the workplace and its specific findings and
for employee involvement. It notes that work is the central institution
in American society ("more Americans work than vote") and we spend
more time at the workplace than any other advanced country, save Japan.
The workplace anchors the nation's economic performance. A skilled,
workforce is our main national asset as it affects economic growth,
quality, and international competitiveness.18
The Commission acknowledged the need for cooperation, and the great
in the seven million workplaces in the country. The use of law and
to bring fairness and safety into the workplace has often been resisted
by management, leading to cases clogging administrative agencies and
courts, delays in decisions, and great distress for workers,
the least well paid. Many workers may know they have rights, but lack
legal, financial, and emotional resources to press for their rights in
legal and administrative settings. Ultimately, many of their concerns
be quickly handled at the workplace level, and the Commission strongly
that improved dispute resolution procedures be implemented in the
Dramatically, the Commission calls for a truce:
It is time to turn down the decibel count, the adversarial
hostility quotient that all to often mars discussion of
relations. We must "come and reason together" to devise the best
ways to assure that workers have their legislatively proscribed and
agreed upon rights and employment norms, without burdening the economy
excessive litigation and extended administrative proceedings. We must
institutions and practices that will allow employees and firms to
at the workplace in ways that will contribute optimally to economic
and competitive performance and to the fulfillment of social norms.
The Commission developed 10 "Goals for the 21st Century Workplace"
as well as specific recommendations for distinct classes of workers
as workers in non-unionized workplaces, contingent workers, and
workers. It reaffirmed that workers need an independent voice for
yet for companies to remain competitive they need ways of collaborating
with their workers which do not break the law.
The Commission viewed its goals and recommendations as a whole cloth,
cautioned against parties picking and choosing the recommendations they
like best to advocate for while ignoring the others. It worked
to distill its proposals to their simplest and most basic forms in
to make their discussion and adoption easier. It encouraged all parties
to adopt a "mutual gains" perspective about the recommendations.
Commissioner Thomas Kochan, of MIT, put it this way:
These potential mutual gains will only be achieved,
if everyone focuses on these opportunities presented in the full report
rather than on specific parts that challenge their prior positions.
employers will not like, but need to face, the finding that labor law
not working to protect individual employee rights to join a union. Some
union leaders will not like, but must face, the fact that many
employees want to participate in cooperative efforts with employers
the protections a union offers.19
The Commission submitted these goals for the 21st century workplace:
1. Expand coverage of employee participation and
partnerships to more workers and more workplaces and to a broader array
The first four goals relate directly to rights and law within the scope
of the National Labor Relations Act. Specific recommendations proposed
2. Provide workers an uncoerced opportunity to choose, or not to
a bargaining representative and to engage in collective bargaining.
3. Improve resolution of violations of workplace rights.
4. Decentralize and internalize responsibility for workplace
5. Improve workplace safety and health.
6. Enhance the growth of productivity in the economy as a whole.
7. Increase training and learning at the workplace and related
8. Reduce inequality by raising the earnings and benefits of workers in
the lower part of the wage distribution.
9. Upgrade the economic position of contingent workers.
10. Increase dialogue and learning at the national and local levels.
nonunion employee participation programs should not be
simply because they involve discussion of terms and conditions of work
compensation where such discussion is incidental to the broad purposes
This idea drew a statement and pointed dissenting opinion from
member Douglas A. Fraser, a former president of the United Auto Workers
(UAW). Fraser views Section 8(a)(2) as a bulwark against illegitimate
of representation which deny workers a voice, and fears that any
of its protections may be subject to abuse. He agrees with Robert
opinion that without these protections management ends up sitting on
sides of the table. In clear language Fraser makes his point:
The recommendation clarifying Section 8(a)(2), the distinction between
employee involvement programs and unions, the protections afforded
in participation programs, and the functions of these programs compared
to unions will by themselves improve the climate for these programs to
In no event, should employer-dominated employee
plans be permitted merely because they are limited to dealing with
subjects such as safety and health or training. Employer-dominated
is undemocratic regardless of the particular subjects with which the
Thus Fraser, apparently alone among the Commission's thirteen members,
the vital importance "voice" played in the crafting of the Wagner
Act and the need for continued vigilance in the current review of
policies and practices.
Senator Nancy Kassebaum (R-Kansas) and Rep. Steve Gunderson
sponsored the Teamwork For Employees and Managers Act of 1995 (TEAM
H.R. 743 and S. 295). They first submitted this bill in 1993, and then
it after the 1994 elections. The bill sought to amend the Wagner Act
8(a)(2) by inserting the following:
Provided further, That it shall not constitute or be
of an unfair labor practice under this paragraph for an employer to
assist, maintain, or participate in any organization or entity of any
in which employees who participate to at least the same extent
as representatives of management participate, to address matters of
interest, including, but not limited to, issues of quality,
efficiency, and safety and health, and which does not have, claim, or
authority to be the exclusive bargaining representative of the
or to negotiate or enter into collective bargaining agreements with the
employer or to amend existing collective bargaining agreements between
employer and any labor organization, except that in a case in which a
organization is the representative of such employees as provided in
9(a), this proviso shall not apply;22
In the middle of May 1996, then Senator Robert Dole, called this
a "very minor piece" and a "sliver" of the total package
(which linked increasing the minimum wage with ending the gas tax). He
President Clinton would sign the whole package with the TEAM Act
Dole underestimated the red flags this legislation would raise for
labor, which launched an all-out grassroots lobbying campaign to
its enactment into law.
Organized labor had a right to be concerned. This bill, as written,
worker's voice and increases the employers' ability to craft any
it wanted and then hand-pick the employees who would be allowed to
to at least the same extent practicable as representatives of
In other words, what had happened in the Electromation case would have
legal. The Republican goal of decreasing workers' voice was underscored
when it blocked an amendment by Rep. James Moran (D-Virginia) which
have permitted workers themselves to chose who represented them on a
committee. Democrats, nevertheless, were successful in splitting the
Dole had tied around the minimum wage bill. This meant that the minimum
wage increase, the repeal of the gas tax, and the TEAM Act would be
on as separate bills.24
By late spring, the final version of the bill had passed both houses of
Congress, but by thin margins (221-202 in the House and 53-46 in the
As expected, on July 30, President Clinton vetoed the bill. He said
legislation, rather than promoting genuine teamwork, would undermine
system of collective bargaining that has served this country so well
many decades" and "rather than encouraging true workplace cooperation,
this bill would abolish protections that ensure independent and
representation in the workplace."25
A regulatory agency, the courts, legal scholars, a Presidential
and Congress have wrestled with this issue. Most of the best ideas have
been presented somewhere within these discussions. I see my task in
section as selecting the best of what has been offered, and when I can,
contributing a few of my own.
The criteria for my selected recommendations include: does it
the power management has in setting the tone within the workplace; does
it serve to promote independent means for workers to choose their own
does it provide an independent means for quickly settling disputes; and
does it protect the most vocal employees who support unions or advocate
for independent worker organizations?
1. Offer every worker in every workplace with more than 25 employees
opportunity to make an informed and active choice about the form of
governance he or she wants.
2. Should employees not choose an independent union, they still must
by secret ballot any employees who serve on joint management-worker
with a breadth of purpose beyond an individual worker or a single team.
3. Institute independent Participation Centers where all workers can
with representatives of the legal profession and unions to discuss
governance options and their likely impact on their workplaces.
4. To allow some flexibility in workplace governance, and to represent
views of workers hired after a particular governance option has been
write into any workplace governance agreement a specific period when it
would be re-selected, changed or dropped by workers. In other words, in
any particular workplace, after so many years, the selected governance
would be up for a new vote.
5. In many workplaces, management's hostility towards unions creates a
in which employees are afraid of being fired or ruining their careers
they express their true feelings about unions or the ability of
to keep its promises. This corrupts any governance decisions made under
these conditions. When a campaign has begun to select a governance
the Participation Centers and the Board should survey employees about
atmosphere within their workplace. Any workplace showing a high degree
fear should be closely monitored, and any employee dismissals or
actions should be immediately evaluated by the nearest Participation
as a possible violation of that worker's workplace and Constitutional
If a worker claims he or she was dismissed because of his or her views
workplace governance, the company should pay at least eighty percent of
the worker's salary pending settlement of the claim.
6. Improve resolution of violations of Constitutional rights in the
As citizens, every worker must be able to enjoy the rights of free
and assembly within any institution (including workplaces) under the
of the Constitution. Should an employer be found to have violated a
Constitutional rights, not only should the worker be restored to his or
her former position and salary, with compensation for his or her
distress, the employer should also pay a fine to the Participation
Alternative dispute resolution procedures can be discussed and voted on
in every workplace along with the workers' elections for
7. Now is the time for union to organize towards helping workers insist
that they can exercise their Constitutional rights in the workplace.
under 15 percent of the workforce belong to unions, our work habits and
expectations are 100 percent unionized. The forty-hour workweek, paid
health benefits, the five-day workweek, and safe working conditions
not showered down upon workers because of the beneficence of
have been wrought from management by unions, and then mimicked by
of non-union workplaces as inoculation against their workers seeking
representation. With forty-four percent of workers willing to belong to
unions if it would mean better representation for them in the
unions have an opportunity. Unions should change how they recruit, and
the mix of "benefits" an associate member from a non-unionize
worksite can expect. High among those new benefits should be legal
and financial support if an associate member is harassed or fired for
out in their non-union workplace.
The difficulty comes down to very simple statements: unions help give
a voice-management doesn't like for workers to have an independent
voice. This internecine and unnecessary conflict hurts everyone. Louise
Parker in an article on how nurses manage the tension between voice and
exit pointed out that
It is not only individual workers who stand to suffer when
are not given some control over decision making, but also
Workers who are depressed are not likely to be productive. Moreover,
members' dissent could lead to organizational learning and improvement.
By not giving workers a voice, organizations stand to lose a
highly valuable source of constructive feedback.26
I join with Dunlop Commissioner Thomas Kochan in calling for a
for mutual gains. Such a coalition would improve the climate for
relations at the national and workplace level. A climate of trust and
will would support experimentation with new approaches to workplace
participation, and representation.27
Trust is not something we ask for and it's delivered. Trust must be
up and is both beautiful and a necessary pre-condition for widespread
prosperity.28 But it is a social art, like a duet in dance. It may be
for a time but if one partner misses a part or loses interest the piece
fails to continue. It takes positive good will on the part of each
and mutual support which allows the other to risk and admit
(a need for learning) without fear. As Churchill said, "Americans will
do the right thing after they have tried everything else." The other
ways have brought us to the current impasse; it is time to give trust a
1 Moe, Participatory Workplace Decisionmaking p. 1173.
2 Ibid., p. 1178.
3 Ibid., p. 1180.
4 Ibid., p. 1182.
5 Ibid., p. 1183-1184.
6 Freeman, Richard, and Rogers, Joel. Final Findings. Available on the
7 Barenberg, Mark. (April 1994). Democracy and Domination in the Law of
Workplace Cooperation: From Bureaucratic to Flexible Production. 94
Law Review, pp. 957-959.
8 Ibid., p. 962.
11 Ibid., p. 964.
13 Ibid., p. 965.
14 Ibid., p. 983.
15 Ibid., p. 758.
16 Dunlop Commission, Available on the World Wide Web, Preface, p. 1.
17 Ibid., pp. 1-2.
18 Ibid., Section 1, p. 1.
19 Kochan, Thomas. (1995). Using the Dunlop Report to Full Advantage: A
Strategy for Achieving Mutual Gains. Available 10/8/96 at:
20 Dunlop Commission, Section 2, pp. 4-5.
21 Dunlop Commission, Dissenting Opinion of Douglas A. Fraser, in
2, p. 12.
22 Teamwork for Employees and Managers Act of 1995 (TEAM Act, H.R. 743
S. 295), Available 10/8/96 at
23 Online NewsHour. (May 14, 1996). Power Plays. Available 10/26/96 at
24 News of the Day. (May 17, 1996). Issue Focus: TEAM Act Debuts in
Campaign. Available 10/22/94 at
25 Budd, J, TEAM Act Web Materials, available on the World Wide Web.
26 Parker, When to Fix It, p. 956.
27 Kochran, Section 3.
28 See Fukuyama, Francis. (1995). Trust: The Social Virtues and
of Prosperity. New York: The Free Press.
Barenberg, Mark. (May 1993). The Political Economy of the Wagner Act:
Symbol, and Workplace Cooperation. 106 Harvard Law Review, 137-1498.
Barenberg, Mark. (April 1994). Democracy and Domination in the Law of
Cooperation: From Bureaucratic to Flexible Production. 94 Columbia Law
Commission on the Future of Worker-Management Relations. (May 1994).
Finding Report. Washington, DC: U. S. Department of Labor.
Dougherty, Laurie. (1993). Jack and Me: A Review of the GE Revolution.
and Sense, September/October1993:12-15.
Freeman, Richard, and Medoff, James L. (1984). What do Unions Do? New
Fukuyama, Francis. (1995). Trust: The Social Virtues and Creation of
New York: The Free Press.
Moe, Martin T. (November 1993). Participatory Workplace Decisionmaking
the NLRA: Section 8(a)(2), Electromation, and the Specter of the
Union. 68 New York Law Review, 1127-1186.
National Labor Relations Board. (December 1992). Electromation, Inc.
International Brotherhood of Teamsters, 309 NLRB 990-1019.
National Labor Relations Board. (1993). A Guide to Basic Law and
Under the National Labor Relations Act. Washington, DC: Government
Nelson, Daniel. (1975). Managers and Workers: Origins of the New
System in the United States, 1880-1920. Madison, WI: University of
Parker, Louise E. (1993). When to Fix it and When to Leave:
Among Perceived Control, Self-Efficacy, Dissent, and Exit. Journal of
Scott, William and Hart, David K. (1990). Organizational Values in
New Brunswick, NJ: Transaction Publishers.
Stonesifer, J. Richard. (1993). The "Boundaryless" Company: A
General Electric Initiative. In Brennan, Niall, editor. Challenging
Thinking for Competitive Advantage. New York: The Conference Board, pp.
U.S. Department of Labor. (August, 1993). High Performance Work
and Firm Performance. Washington, DC: Office of the American Workplace,
U. S. Department of Labor. L 1.2:P 41/993 Seattle LIB
World Wide Web
Bouyea, Bob. (1995). Three Professors are Targets of Cat Letter.
Budd, J. (1996). TEAM Act Web Materials for use in IR 8007 and IR 8037,
(1996). Available 10/10/96 at
Finamore, Carl. (1996). Labor History for Workers. Available 10/24/96
The Commission of the Future of Worker-Management Relations (Dunlop
(1995). Report and Recommendations. Available 10/8/96 at
Freeman, Richard and Rogers, Joel. (1994a). First Report of the
Available on 10/17/96 at
Freeman, Richard, and Rogers, Joel. (1994b). Worker Representation and
Survey-Final Findings. Available 10/17/96 at
Grob, H. (1995). Worker Representation and Participation Survey
Available 10/17/96 at
LPA. (1996). U.S. Employment Laws. Available 10/24/96 at
Labor-Management Relations. Available 10/24/96 at
Labor Relations and Employment Law Speakers. Team Building: The Future
Now. Available 10/8/96 at http://www.mesirov.com/itlabels.htm,
Lutins, Allen. (1995). An Eclectic List of Events in the U.S. Labor
Available 10/24/96 at http://www.nitehawk.com/alleycat/labor.html.
News of the Day. (May 17, 1996). Issue Focus: TEAM Act Debuts in
Campaign. Available 10/22/94 at
Online NewsHour. (May 14, 1996). Power Plays. Available 10/26/96 at
Peck, Ira. (1991). Labor in America. Available 10/24/96 at
TEAM Act Myth vs. Fact, Available 10/8/96 at
U.S. Congress. (1996). Teamwork for Employees and Managers Act of 1995
Act). H.R. 743 and S. 295, 104th Congress, Second Session. Available
Wimberly, Jim. (1996). What Are Employers to Do About the Legal
of Employee Involvement Groups? Available on 10/8/96 at
Video and Film
Norma Rae. (1979). Directed by Martin Ritt. 20th Century Fox.
The Uprising of '34. (1996). Produced and directed by George Stoney,
Helfand and Susanne Rostock, New York: First Run-Icarus.