HCBA Lawyer Magazine Vol. 29, No. 4 | Page 49

aCCoMModaTing Taking a knee To pregnanCY-relaTed Free speeCH in THe workplaCe liMiTaTions labor & Employment law Section Continued from page 46 which is protected by federal and state labor laws. Many employers are not sure where they can draw the line. For example, the Dallas Cowboys recently faced an unfair labor practice charge because their owner, Jerry Jones, told players that they may no longer take a knee during the national anthem to protest political or social issues. Even though Jones did not threaten termination, he nonetheless made it clear that he would take adverse action against his players — i.e., benching them — if they did not stand during the national anthem. Jones’ actions made national headlines and prompted Local 100 of the United Labor Unions to file an unfair labor practice charge against the Cowboys with the National Labor Relations Board (NLRB), claiming the threat to bench players chilled protected concerted activity. But Local 100 withdrew the charge because, in order to succeed, the Cowboys players would have been required to show that they kneel during the national anthem to protest the terms and conditions of their employment, rather than the ongoing political and social issues relating to the treatment of African Americans by law enforcement, which issues have permeated the news since at least mid-2016. Jones’ actions and Local 100’s response raise a critical issue: what are the limits on employees exercising their right to engage in concerted activity by engaging in controversial, unpopular, or even profane speech? In Nat’l Labor Relations Bd. v. Pier Sixty, LLC, 855 F.3d 115, 117 (2d Cir. 2017), the Second Circuit provided employees substantial leeway to engage in such speech. In Pier Sixty, an employee on break posted a profanity-laced rant on social media regarding his boss and his boss’ mother. Because the employee inserted the words “Vote YES for the UNION” in the same post, the Second Circuit held that the employee’s termination for making the post constituted an unfair labor practice. While Pier Sixty does not support the conclusion that an employee may immediately take to social media to berate his or her boss or boss’ family, or otherwise disrupt the workplace with such speech, it does show the broad deference courts give the NLRB in protecting an employee’s right to engage in concerted activity. In today’s divisive political climate, labor and employment law practitioners, as well as in-house counsel, should ensure that their clients or employers are well-versed in these matters to avoid taking a knee to unprotected speech. Authors: Gregory A. Hearing & Matthew A. Bowles – Thompson, Sizemore, Gonzalez & Hearing, P.A. MAR - APR 2019 | HCBA LAWYER 47