Save Your Soliciting for Snack Time


The United States Court of Appeals for the Eighth Circuit (the “court”) (ConAgra Foods, Inc. v. NLRB, 813 F.3d 1079 (8th Cir. 2016)) recently overturned a decision of the National Labor Relations Board (the “NLRB”) which had held that a brief comment about an authorization card by one employee to fellow employees, without actually presenting a card to those employees, did not amount to solicitation.
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Hospitals Must Allow Email Solicitations


In a decision issued last year (Purple Communications, Inc., 361 N.L.R.B. 126 (2014)), the National Labor Relations Board (NLRB) held that, barring special circumstances, an employer who allows its employees access to the employer’s email system must also allow its employees access to the email system, during non-working time, for solicitations authorized under Section 7 of the National Labor Relations Act.
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