Although secondary activity directed against neutral employers is mostly unlawful, secondary activity isn’t the only way for a union to try to gain leverage against an employer with which the union has a dispute. Sometimes a union will engage in picketing and handbilling directed at consumers to put additional pressure on a primary employer.

I. Consumer Picketing

Consumer picketing is lawful but subject to some restrictions.

Suppose a union was on strike against a group of fruit wholesalers...