join one union and not to join other labor organizations, as well as many other forms of conduct.

The evidence showed that the company had employed labor spies to report on the growth of a new union and to interfere with the independent organization of workers. This, the court said, constituted support of a labor organization in violation of the Labor Relations Act. There was also evidence that, in the course of a strike at Johnstown, Pa., in 1937, the employer had turned over money to the mayor of that city to insure the continuance of his hostility to outside unions. The company also promised money to a so-called "Citizens' Committee" which, in the name of law and order, sought to break the strike. All of these forms of conduct were held to show that the employer had contributed to the support of the Plans; therefore, the order of the Board disestablishing the Plans was held to be valid.

In a dissenting opinion, Mr. Justice Stephens declared that there was no evidence of domination by the employer, and, further, that a new hearing should be granted by the Board because of an alleged bias on the part of the trial examiner. The court in the majority opinion declared that the examiner had not shown bias or prejudice and that the employer had been granted a fair hearing.

Payment of Compensation Accruing After Employee's Death

An interesting case concerning workmen's compensation was recently decided by the Court of Civil Appeals of Texas. The case concerned an award payable in weekly installments for general injuries received by a worker. The employee died prior to the expiration of the compensation period, and the question arose as to whether the heirs of the deceased employee were entitled to the unpaid compensation award.

The court held that where an employee receives a "specific injury" such as the loss of an eye, and the award of compensation is payable in weekly installments, the right to the full amount of the award is a "vested right." Therefore, in such a case, if the employee dies prior to the expiration of the compensation period, his heirs are entitled to the installments accruing after his death. On the other hand, an employee who is awarded compensation for a "general injury," has no "vested right" in the full amount of the award, and his heirs cannot recover the unpaid installments accruing after his death. In this particular case of general injury, however, the heirs were permitted to recover because the insurer had failed to make the weekly payments required by the award of the industrial accident board prior to the employee's death. By failure of the insurer to make the payments, the statute gave the employee a "vested right" in the entire amount of the award.

1 Southern Underwriters v. Lewis (150 S. W. (2d) 162).

CHANGES IN COST OF LIVING, APRIL 15 TO

MAY 15, 1941

THE cost of living in large cities rose by 0.7 percent between midApril and mid-May, largely because of increases in food costs, in rents, in prices of men's work clothing and of gasoline. This advance brings living costs of moderate-income city families to a point 2.4 percent above the level of last June and 4.4 percent above August 1939. The cost of food to city workers again rose by 1.5 percent between mid-April and mid-May. Prices of fresh fruits and vegetables increased, as is usual at this time of year. Higher prices for pork products, eggs, evaporated milk, and cheese resulted from the continued rise in consumer incomes and large Government purchases made at prices intended to encourage increased production. Advances in wholesale prices of butter were reflected in the retail prices. The general reduction in shipping facilities contributed to increases in the cost of sugar, coffee, and tea.

At the end of May preliminary reports on prices of 18 staple foods indicated that lard, egg, butter, coffee, and navy bean prices had registered further increases.

As compared with prices in mid-May of last year, fresh fruits and vegetables averaged about 2 percent lower, with oranges 9 percent and potatoes 24 percent lower than in May 1940. Prices for eggs and butter were, however, about 20 percent higher, and meats, coffee and tea, fats and oils, and sugar were from 2 to 10 percent higher. Canned fruits and vegetables were 1.5 to 2 percent higher this May than in May a year ago. On the average, the cost of food to wage earners and clerical workers in large cities was 5.3 percent above the level of midMay last year; and 9.2 percent above August 1939, when food costs were at a comparatively low level for recent years.

Rents charged moderate-income families rose again on May first. The increases resulted in a rise in average rents of four-tenths of 1 percent in the 20 large cities surveyed monthly. The most pronounced increases occurred in Chicago and Seattle. There were scattered increases in clothing prices. Because of large Government purchases for the Army, and generally higher wholesale prices for cotton fabrics, retail prices for men's overalls and work

shirts increased generally. Increases in prices for men's overalls averaged about 1 percent for the month, carrying the level about 10 percent above that of August 1939. Increases in prices for work shirts averaged about 3 percent between April 15 and May 15, but the rise since August 1939 has not been so marked as in the case of overalls. The most pronounced advances in prices of men's suits and men's work clothing occurred in Baltimore and Seattle, where there were continued large increases in employment. In Seattle, in addition there were general price increases because of an advance in the sales tax from 2 to 3 percent on May 1.

Advances in furniture costs were reported in 18 of the 20 cities from which the Bureau of Labor Statistics obtains monthly data. Increases in refrigerator prices in 7 cities brought the average large-city price back to that prevailing last September, when price cuts were announced by a number of manufacturers. Rug prices, which are to a large extent dependent on availability of imported carpet wools, rose further in a number of cities, bringing the average for May 15 more than 5 percent above June 1940 and almost 20 percent above August 1939.

Increases in prices of gasoline were reported from 15 of the 20 cities. covered by the Bureau's monthly survey. In these cities the advances averaged 0.8 cent per gallon.

TABLE 1.-Percent of Change From April 15, 1941, to May 15, 1941, in the Cost of Goods Purchased by Wage Earners and Lower-Salaried Workers

Estimated percent changes from April 15 to May 15, 1941, in the cost of goods purchased by wage earners and lower-salaried workers in 20 large cities of the United States, and for the large cities combined are presented by groups of items in table 1. Table 2 presents estimated indexes of these costs, as of May 15, 1941, based on average costs in the years 1935-39 as 100.

TABLE 2.-Indexes of Cost of Goods Purchased by Wage Earners and Lower-Salaried Workers, by Groups of Items, May 15, 1941

RECENT STRIKES

ACCORDING to preliminary estimates there were 500 new strikes in May 1941 in which 315,000 workers were involved. There were 24 million man-days of idleness during all strikes in progress in the month. These figures represent an increase of 25 percent in the number of strikes but decreases of 37 percent in number of workers involved and 71 percent in man-days of idleness, as compared with April, when the general bituminous-coal stoppage was in progress. The number of strikes in May was greater than in any month since June 1937.

Excluding the general bituminous-coal stoppage, the amount of idleness during strikes in May was 20 percent less than in April, although the number of workers involved in May strikes was about 72 percent greater than in April. The largest strikes beginning in May, in terms of the number of workers involved, were the 1-day stoppage of anthracite miners in Pennsylvania, a brief stoppage of workers at several General Motors Corporation plants in Michigan, the strike of several thousand building-trades workers in and around Detroit, Mich., and the strike of shipyard workers (machinists) at San Francisco.

The estimates for May are shown in the table below along with figures for other periods for comparison.

Strikes in April and May 1941 Compared with Averages of Preceding 5-Year Period