There was no real national labor movement in the 1840s, but there was certainly no shortage of local labor disputes and attempts (some successful) at improving working conditions through organization and even strikes. Most labor strife, predictably, was located in the Northeast, the first area to industrialize in the United States. Attempts to organize made very halting but significant gains, with workers winning the right to organize in Massachusetts, at least in the 1842 case Commonwealth v. Hunt, heard before the state Supreme Court. Some states even passed laws regulating labor conditions and allowing for maximum hours in one week. On the other hand, the period also saw the rise of sweatshops in the garment industry (which was still not really mechanized during this period) and lowered wages, as workers driven out of skilled crafts by better capitalized factories faced competition for wage laboring jobs from the steady flow of immigrants during the period.