National Labor Relations Board v. Magnavox Co. of Tennessee

Magnavox Co. of Tennessee (Magnavox) (defendant) had a rule prohibiting employees from distributing literature on any of its property at any time. The International Union of Electrical, Radio, and Machine Workers (the union) (plaintiff) became the exclusive collective-bargaining representative of Magnavox’s employees and, as reiterated in multiple collective-bargaining agreements, authorized Magnavox to issue fair and nondiscriminatory rules for maintaining orderly conditions on plant property. Magnavox also agreed to make bulletin boards available for union notices, subject to the company’s right to reject controversial notices. Magnavox accordingly maintained a ban on employees’ distribution of literature on company premises, including in nonwork areas during nonwork times (the ban). Years later, the union requested a change to the ban, which Magnavox denied. The union filed unfair-labor-practice charges against Magnavox, and the National Labor Relations Board (the board) found that the ban was unlawful. The court of appeals denied enforcement of the board’s order, finding that the union had waived objection to the ban through its collective-bargaining agreements. The matter came before the Supreme Court, which had to decide whether the union was able to waive employees’ protected rights under the National Labor Relations Act.