In these tough economic times, many unionized employers are carefully considering their options to get rid of union collective bargaining agreements. Many employers assume that by

simply shutting down the business, collective bargaining agreements may be terminated and struggling businesses may be resuscitated. The recent decision of Barker v. Conner, Inc. out of the Northern District of Illinois is a classic example of an employer jumping from the frying pan into the fire and accomplishing nothing but the creation of back pay liability to add to their financial woes.