Abstract
This article compares the development of the workers' right to organize and bargain collectively in England, France, and the U.S. Starting with a common repressive policy, each country followed a different path toward establishing the workers' rights. The main ultimate difference lies in the extent to which the state became involved in industrial relations. In England the state remained aloof after securing very broad legal rights of collective action. The workers were left to do their own battling. In France the state came to look upon collective agreements as an aspect of public policy and became the dominant partner in labor negotiations. The American pattern lies in between: state protection extends to procedural but not to substantive issues.
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