Inc. v. NLRB Lechmere

In rendering its decision in Lechmere, Inc. v. NLRB the U.S. Supreme Court held that private property rights could not be superseded even when non-employee organizers engaged in trespassing on private company property to solicit employee involvement in union-sponsored, self-organization. Stressing that the National Labor Relations Act (NLRA) conferred rights only to employees (not to non-employee organizers), the Court produced a ruling which reset boundaries in which organized labor could operate. Lechmere, Inc. (and, therefore, all employers) could bar union organizers from its property, whenever there existed alternative methods of communication with employees in order to inform them about their rights to organize. Accommodation of efforts by labor unions did not always entail unequivocal access to employer-owned property. The Court explained that "non-employee organizational trespassing had generally been prohibited except where unique obstacles prevented nontrespassory methods of communication." Justices thus held that provisions of the National Labor Relations Act were enforceable only if employees were "beyond the reach of reasonable union efforts to communicate with them." Private property rights otherwise superseded the right of unions efforts to enable self-organization by employees.