Mr. Moreland, in his earlier testimony, admits to this fact as being true. The jury in this case agreed that the master shoemakers, the journeymen, and the public were endangered by the association of journeymen and returned a verdict of guilty of conspiracy, although the court fined the defendants only $1 each, plus prosecution costs. The early craft societies, mainly shoemakers and printers, were typically transitory. Cyclical economic downturns routinely dissolved worker collective actions, and wage reductions, though resisted, were common during downturns in the economy. Another deterrent to unionization came from court actions. Conservative judges, in their instructions to juries, contended that union action per se was illegal. "Commonwealth v. Morrow" was first of many of the legal cases that challenged the "common law police power maintained in many of the preceding cases." The case largely followed what had by now emerged as a normal pattern—prosecution disclaimers of hostility to the journeymen and promises of a light penalty. The case was a breakthrough in that the court indicted the defendants, not for demanding high prices, but for employing unlawful means to extort those prices. It also redefined the definition of conspiracy as a "combination to effect an unlawful purpose or to effect a lawful purpose by unlawful means. Threats and violence would qualify as conspiracy, but not the simple act of writing and adopting a constitution or a collective refusal to work unless a nonmember were discharged.”  "Commonwealth v. Morrow" was one of the many cases that helped transform labor unionization from an act of conspiracy to legitimate means of personal expression. Over the next few years, the apparent precariousness of the journeymen's legal position would become somewhat qualified, as sum by the decline in the incidence of prosecution regarding unionization and collective bargaining of wages.