The Supreme Court cases of Republic Aviation Corporation v. NLRB and NLRB v. Le Tourneau Co. of Georgia are significant in the context of labor relations. The former case, decided in 1945, involved Republic Aviation Corporation, a non-urban manufacturing establishment for military production that employed thousands and was rapidly growing. The National Labor Relations Board (NLRB) had found that workplace restrictions on Section 7 communications that applied during nonwork time were presumptively unlawful. The Supreme Court upheld this decision, stating that employees must have adequate avenues of communication for expressing their concerns and engaging in protected concerted activities.
On the other hand, NLRB v. Le Tourneau Co. of Georgia, decided in 1965, dealt with an employer's no-solicitation policy that prohibited union solicitation during nonworking hours in areas where work was performed. The Supreme Court held that the policy was valid, as it furthered the employer's interest in maintaining production and discipline. This decision overruled the NLRB's previous position that such policies were unlawful, as established in the Republic Aviation case. The Court in Le Tourneau emphasized that the extent and character of the restrictions imposed by the rule must be considered, and that a case-by-case approach should be taken in evaluating the reasonableness of such rules. Overall, these two cases highlight the evolving nature of labor law and the ongoing tension between employees' rights to engage in protected concerted activity and employers' interests in maintaining order and productivity in the workplace.