Collective and organized ostracism applied in labour, economic, political, or social relations to protest and punish practices considered unfair. The tactic was popularized by Charles Stewart Parnell to protest high rents and land evictions in Ireland in 1880 by the estate manager Charles C. Boycott (b. 1832d. 1897). Boycotts are principally used by labour organizations to win improved wages and working conditions or by consumers to pressure companies to change their hiring, labour, environmental, or investment practices. U.S. law distinguishes between primary boycotts, which consist of the refusal by employees to purchase the goods or services of their employers, and secondary boycotts, which involve attempts to induce third parties to refuse to patronize the employer. The latter type of boycott is illegal in most states. Boycotts were used as a tactic in the U.S. civil rights movement of the 1950s and '60s and also have been applied to influence the conduct of multinational corporations.