Labor relations today, are quite different from those that existed in England during the eighteenth and nineteenth centuries when employment relationships were considered of very little importance in the eyes of the law. Industrialization and commerce grew bringing with it the birth of modem day labor law. America was in no way exempt from the pain of progress. Employer and employee relationships were strained from the very beginning of labor, and it soon was evident that government intervention would be necessary to keep the labor movement on track. Several statues have been enacted since the early nineteenth century to deal with management and unions. Evidence can be seen from the Norris-La Guardia to the Wagner Acts, which protected unions from anti-trust laws, the Taft-Hartley Act, designed to protect employers from union abuses. The struggle of growth slowly gave away to one conflict after another. Even today, both employers and unions continue to fight for the most advantageous positions from which to bargain. In the last decade one of the most prominent issues to emerge on the horizon has been the whistle-blowing phenomenon (Efrim 52). The term whistle-blowing may apply to employees in a wide variety of circumstances from staff officers to line workers. The most common report is from an employee that discloses unauthorized information that they believe is evidence of a violation of law, rule or regulation, code or practice, or that involves mismanagement, corruption, abuse of authority, and danger to the public or worker's health and safety (Vinten 44). Although whistle-blowing is generally used in a broad sense, the person who actually comes forward may be categorized into three basic types: (1) The passive whistle-blower - includes employees who do nothing more than respond when asked for information by government authorities or those who refuse to carry out illegal instructions given by their emp...