| 1. James Edmund Boyd (1845-1935) was U.S. district judge for the Western District of North Carolina, serving from 1900 until his death. 2. On Aug. 22, 1921, Boyd granted an injunction to prevent collection of a federal penalty tax from a North Carolina firm that employed child labor, ruling that the Child Labor Tax Act, which authorized the penalty, was unconstitutional (George v. Bailey, 274 F. 639 [1921]). On appeal, the U.S. Supreme Court reversed Boyd's decision on procedural grounds and ordered the case dismissed (Bailey v. George, 259 U.S. 16 [1922]). On Dec. 10, 1921, in a case where another manufacturer had already paid the penalty tax for using child labor, Boyd again found the law unconstitutional and ordered the money returned with interest (Drexel Furniture Co. v. Bailey, 276 F. 452 [1921]). On appeal, the U.S. Supreme Court ruled that the Child Labor Tax Act was unconstitutional and upheld Boyd's decision (Bailey v. Drexel Furniture Co., 259 U.S. 20 [1922]). 3. U.S. Statutes at Large, 37: 81-84, passed in 1912. 4. U.S. Statutes at Large, 24: 209-13, passed in 1886 and U.S. Statutes at Large, 32: 193-97, passed in 1902. 5. McCray v. United States, 195 U.S. 27 (1904). 6. The AFL Executive Council met Aug. 22-30, 1921, in Atlantic City. |